- 4 -
issued. An attachment to the determination contained the
following explanation:
In your request for a hearing under IRC Section 6330
you disagreed with the proposed levy action because you
filed Form 1040 1991 and the liability assessed is
incorrect. During the hearing you stated that you
timely filed your Form 1040 1991 but never received
your refund.
During the hearing the liability was reviewed and
discussed. The disallowed claim was reviewed with you.
You stated you did not file a Form 1040A for 1991. You
provided a copy of your Form 1040 for 1991. Since you
indicated that you did not recall receiving the
Statutory Notice of Deficiency, which our records
verify was mailed certified to you on December 1, 1998,
you were provided with an opportunity to present
information for reconsideration of the liability and
any proof of timely filing the return. No information
was presented by the March 24, 2004 deadline to
reconsider the liability and there has been no
information received to date. The audit
reconsideration procedures were explained to you and
you were provided with Publication 3598, The Audit
Reconsideration Process.
Also during the hearing, you were informed that
collection alternatives could not be considered since
you are not in compliance with the tax filing
requirements.
There were no relevant challenges to the
appropriateness of the proposed collection action.
No other issues were raised.
Petitioner filed a petition and amended petition with this
Court disputing the notice of determination on June 18 and
July 20, 2004, respectively, each of which reflected an address
at 11347 Gabriel, Romulus, MI 48174. The request for relief
proffered in the amended petition read:
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011