- 2 - FINDINGS OF FACT On May 15, 2003, respondent issued petitioner a Final Notice of Intent to Levy and Notice of Your Right to a Hearing relating to 1989 through 2000 (the years in issue). In the notice, respondent determined that petitioner was liable for taxes and additions to tax totaling $130,835 and $41,445, respectively, relating to the years in issue. On May 27, 2003, petitioner timely filed a Form 12153, Request for a Collection Due Process Hearing (request), and stated that he did “not have sufficient assets to cover the assessed liabilities.” On November 11, 2003, petitioner sent respondent a Form 433-A, Collection Information Statement for Wage Earners and Self-Employed Individuals. On November 25, 2003, petitioner supplemented his Form 433-A with copies of statements relating to petitioner’s checking, credit card, and telephone accounts. Petitioner also attached a copy of a statement relating to a car lease in the name of Leo Shrier, petitioner’s father. On November 25, 2003, respondent conducted a telephone conference with petitioner. During the conference, petitioner requested that his account be placed in “currently not collectible status” because he was unemployed. On February 13, 2004, petitioner’s counsel informed respondent that petitionerPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011