Robert B. Keenan - Page 2

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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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