- 5 - were assessed against petitioner for 1989 and 1991 because of the underreporting.4 On August 23, 2002, respondent mailed petitioner a Letter L- 1058, Final Notice of Intent to Levy and Notice of Your Right to a Hearing. The notice informed petitioner that respondent proposed to levy on his property to collect Federal income taxes owed for 1989 and 1991. The notice advised petitioner he was entitled to a hearing with respondent’s Appeals Office to review the propriety of the proposed levy. On August 29, 2002, petitioner submitted a Form 12153, Request for a Collection Due Process Hearing. Petitioner indicated he would pursue an offer- in-compromise based on effective tax administration and would provide financial information upon request. On March 11, 2003, Appeals received petitioner’s original Form 656, Offer in Compromise, with a completed Form 433-A, Collection Information Statement for Wage Earners and Self- Employed Individuals, offering to pay $102,000 to compromise his outstanding tax liability. Petitioner offered to compromise his outstanding 1985-95 tax liabilities on the grounds of doubt as to 4 TBS 1989-1, one of the partnerships in which petitioner invested, was involved in a consolidated case decided by this Court in Durham Farms #1, J.V. v. Commissioner, T.C. Memo. 2000- 159, affd. 59 Fed. Appx. 952 (9th Cir. 2003). As a result of that case, computational adjustments were made, and, on May 13, 2002, additional income tax and interest were assessed against petitioner for 1989 and 1991.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011