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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.
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