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and effective tax administration (December OIC). Petitioner
attached to the December OIC an updated Form 433-A, statements
relating to petitioner’s checking account, statements relating to
an employee profit-sharing plan, and wage statements from his
current employer.
In a letter dated March 3, 2005, respondent stated that the
December OIC was insufficient because petitioner did not provide
the requisite documentation relating to petitioner’s ability to
pay. Respondent also informed petitioner that his claimed living
expenses (e.g., food, housing, and transportation) were in excess
of the allowable amount. Respondent also asserted that
petitioner had not disclosed that he was living with another
individual.
On April 15, 2005, respondent issued petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 relating to 1989 and 1991 through 2000. On May 12,
2005, petitioner, while residing in Aventura, Florida, filed his
petition with the Court relating to the years in issue and 2001.
On July 15, 2005, respondent issued petitioner a Decision Letter
Concerning Equivalent Hearing Under Section 6320 and/or 6330 of
the Internal Revenue Code relating to 1990.
On March 2, 2006, the Court filed respondent’s motion to
dismiss for lack of jurisdiction and to strike as to the taxable
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