Perry Westcott - Page 4

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          30, 2002 telephonic conference) concerning petitioner’s Form                
          12153.  During that telephonic conference, petitioner indicated             
          that he had not filed Federal income tax returns (tax returns)              
          for his taxable years 1999, 2000, and 2001 because he had been              
          unable to find a return preparer whom he could afford to prepare            
          such returns.  Petitioner further indicated during the August 30,           
          2002 telephonic conference that he had just found a return                  
          preparer whom he could afford to prepare tax returns for such               
          taxable years, that such returns would be filed in late September           
          2002, and that the total tax and the tax due shown in peti-                 
          tioner’s 1998 return would be reduced by respective losses to be            
          claimed in such returns.  During the August 30, 2002 telephonic             
          conference, petitioner was informed that, in order to qualify for           
          so-called hardship status, he first must file all tax returns               
          that were then due.  During the August 30, 2002 telephonic                  
          conference, petitioner asked the representative from respondent’s           
          collection division to forward his case to the Appeals Office.              
          Around September 6, 2002, respondent’s collection division                  
          forwarded to the Appeals Office petitioner’s collection matter              
          regarding his taxable year 1998.                                            
               On September 23, 2002, the Appeals officer assigned to                 
          petitioner’s case (Appeals officer) scheduled an Appeals Office             
          hearing with petitioner.                                                    







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