- 2 - Background This is an appeal from respondent’s determination upholding the proposed use of a levy to collect petitioner’s unpaid Federal income tax liability for years 1988 and 1990 through 1994. Petitioner resided in Camarillo, California, when the petition in this case was filed. Petitioner failed to file Federal income tax returns for 1988 and 1990 through 1994.2 Respondent sent statutory notices of deficiency to petitioner for those years, and petitioner petitioned this Court with respect to respondent’s determinations. On March 7, 2003, the Court entered decisions that upheld deficiencies and imposed additions to tax under sections 6651(a)(1) and 6654.3 After the entry of the decisions respondent assessed the income tax deficiencies and additions to tax determined by the Court and interest as required by law and sent petitioner notice and demand for payment. On August 9, 2004, respondent sent petitioner a Notice of Intent to Levy and Notice of Your Right to a Hearing, in accordance with sections 6330 and 6331, informing petitioner of respondent’s intent to 1(...continued) years in issue. 2 It appears petitioner did not file a Federal income tax return for 1989, but that year is not before us. 3 We found petitioner liable for income tax deficiencies of $351,228 and additions to tax under secs. 6651(a) and 6654 of $78,674.50 and $18,652.17, respectively.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011