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not disclosed by the record,4 and interest as provided by law.
(We shall refer to any such unpaid amounts, as well as interest
as provided by law after March 4, 2002, as petitioner’s unpaid
1998 liability.)
On March 4, 2002, respondent issued to petitioner a notice
of balance due with respect to petitioner’s unpaid 1998 liabil-
ity.
On August 17, 2002, respondent sent petitioner a final
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to petitioner’s unpaid
1998 liability.
On August 20, 2002, in response to the notice of intent to
levy, petitioner filed Form 12153, Request for a Collection Due
Process Hearing (petitioner’s Form 12153), and requested a
hearing with respondent’s Appeals Office (Appeals Office). In
petitioner’s Form 12153, petitioner stated:
Taxes owed from 1998 are offset by losses in 1999 &
2000. Cannot find anyone, including IRS, to complete
tax return & we cannot do it ourselves & cannot afford
CPA.
On August 30, 2002, a representative of respondent’s collec-
tion division had a telephonic conference with petitioner (August
4Although not disclosed by the record, we presume that the
additions to tax that respondent assessed were additions to tax
under sec. 6651(a)(1) and (2). That is because petitioner did
not file his 1998 return until July 2, 2001, and did not pay the
tax due shown in that return when he filed it.
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