- 5 - On May 5, 2003, respondent issued to petitioner a notice of balance due with respect to petitioner’s unpaid 1999 return liability. On various dates from May 26 through December 22, 2003, respondent abated certain assessed amounts of petitioner’s tax, additions to tax, and interest as provided by law with respect to petitioner’s taxable year 1999. On various dates after respon- dent made the respective assessments on February 24, 2003, and May 5, 2003, with respect to petitioner’s taxable year 1999, respondent applied as credits to the unpaid total 1999 liability certain overpayments with respect to certain other taxable years of petitioner after petitioner’s taxable year 1999. On February 21, 2004, respondent issued to petitioner a final notice of intent to levy and notice of your right to a hearing with respect to petitioner’s unpaid total 1999 liability. On or about March 8, 2004, petitioner sent a letter (peti- tioner’s March 8, 2004 letter) to respondent that respondent received on March 12, 2004. That letter stated in pertinent part: Letter of Protest * * * * * * * 2. I state that I want to APPEAL the IRS find- ing to the Appeal Office.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