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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
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Last modified: May 25, 2011