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Background
Petitioner failed to file a Federal income tax return for
2000. On August 21, 2002, respondent sent petitioner a statutory
notice of deficiency for 2000.
On March 10, 2003, respondent assessed a deficiency in tax
and additions to tax for the taxable year 2000 and issued to
petitioner a notice of assessment and demand for payment. On
June 21, 2003, respondent mailed to petitioner a Final Notice of
Intent to Levy and Notice of Your Right to a Hearing concerning
the 2000 tax liability. Petitioner timely filed a Form 12153,
Request for a Collection Due Process Hearing, which stated that
he was “Not Liable”.
On June 4, 2004, a hearing was held. Petitioner did not
propose any collection alternatives at the hearing. On July 22,
2004, respondent issued a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 to petitioner
regarding his 2000 tax year.1 In the notice of determination,
respondent determined that the proposed collection action was
appropriate and to proceed with collection.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011