- 3 -
submitted a Form 12153, Request for a Collection Due Process
Hearing. His case was assigned to an Appeals officer, who sent
petitioner a letter requesting information and scheduling an
administrative hearing for October 8, 2003. Petitioner did not
attend the hearing.
The Appeals officer and petitioner thereafter exchanged
correspondence. Petitioner initially raised a spousal defense
under section 6015, but abandoned this argument because he did
not file joint tax returns for the years at issue. Petitioner
indicated that he was unable to pay his tax liabilities but did
not provide financial information that the Appeals officer had
requested. Petitioner also sought to challenge his underlying
tax liabilities, asserting that the tax reported on his 1994
through 1999 tax returns was incorrect. Petitioner made various
contentions about losses incurred in connection with oil and gas
interests in Texas; however, he did not provide the Appeals
officer with information concerning these interests. The Appeals
officer informed petitioner that if he wished to dispute his
underlying tax liabilities, he should file amended returns.
Petitioner did not file an amended return for any of the years at
issue.
Respondent issued petitioner a notice of determination on
October 31, 2003, sustaining the proposed levy action. The
notice of determination stated that the requirements of
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011