Barry Shrier - Page 2

                                        - 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 petitioner              






Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011