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Respondent issued notices of final partnership
administrative adjustments (FPAAs) to DGE 85-1 and SGE 85-1 for
their 1985 and 1986 taxable years.6 After completion of the
partnership-level proceedings, respondent determined deficiencies
in petitioner’s income tax for his 1982 through 1986 tax years.
On January 24, 2002, respondent issued petitioner a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing (final notice). The final notice included petitioner’s
outstanding tax liabilities for 1982 through 1986.
On February 12, 2002, petitioner submitted a Form 12153,
Request for a Collection Due Process Hearing. Petitioner argued
that the proposed levy was inappropriate and that an offer-in-
compromise should be accepted.
Petitioner’s case was assigned to Settlement Officer Linda
Cochran (Ms. Cochran). Ms. Cochran scheduled a telephone section
6330 hearing for March 23, 2004. During the hearing,
petitioner’s representative, Terri A. Merriam (Ms. Merriam),
requested that petitioner be given more time to submit
information to be considered. Ms. Cochran extended petitioner’s
deadline for submitting information to be considered to April 6,
2004.
6 The FPAAs and other information specific to DGE 85-1’s
and SGE 85-1’s partnership-level proceedings are not in the
record.
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Last modified: May 25, 2011