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collection of income tax for the periods of 1989 through 1992.”
The letter also advised petitioner of his appeal rights pursuant
to section 7429.
On June 30, 1999, respondent filed a notice of Federal tax
lien in the Wabash, Indiana County Recorder’s Office regarding
jeopardy assessments of income taxes, interest, and penalties for
1989, 1990, 1991, and 1992. On July 5, 1999, respondent sent to
petitioner a Letter 3172, Notice of Federal Tax Lien Filing and
Right to a Hearing Under IRC Section 6320, regarding petitioner’s
1989, 1990, 1991, and 1992 tax years.
Petitioner executed and mailed to respondent a Form 12153,
Request for a Collection Due Process Hearing, dated July 23,
1999. In that Request for a Collection Due Process Hearing,
petitioner appealed both the notice of Federal tax lien and the
notice of levy. On September 13, 1999, the Appeals officer sent
a letter to petitioner establishing a conference date of October
20, 1999. By letter dated September 22, 1999, petitioner
requested that the conference be moved to Cleveland, Ohio, where
he was incarcerated.
Sometime between December 8, 1999, and January 11, 2000,
respondent’s Appeals officer and petitioner conducted a telephone
conference regarding petitioner’s request for a hearing. During
the telephone conference, petitioner did not question the amounts
of gross income respondent determined for 1990, 1991, and 1992.
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