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A notice of deficiency for 1991 was thereafter issued to
petitioner and was sent by certified mail to 12079 Plainview,
Detroit, MI 48228-1070792, on December 1, 1998. The notice
reflected an income tax deficiency in the amount of $8,329.10 for
1991 and additions to tax under sections 6651(a) and 6654(a) of
$877.53 and $169.99, respectively. Petitioner did not file a
petition with this Court in response to the notice of deficiency,
and respondent assessed the corresponding taxes, additions to
tax, and interest for 1991 on June 21, 1999. A notice of balance
due was sent to petitioner on that date, as well as on July 26,
1999, and September 24, 2001.
On September 18, 2002, the IRS issued to petitioner a Final
Notice - Notice of Intent to Levy and Notice of Your Right to a
Hearing with respect to his 1991 liabilities. The notice was
sent by certified mail to an address in Romulus, Michigan. In
response, petitioner submitted to the IRS a timely Form 12153,
Request for a Collection Due Process Hearing, expressing his
disagreement as follows: “I have filed 1991 return your computer
is not correct”.
A face-to-face hearing between petitioner and the settlement
officer to whom his case had been assigned was held on March 10,
2004. Following the hearing, on May 21, 2004, the aforementioned
determination letter sustaining the proposed levy action was
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