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On or about August 16, 2004, petitioner mailed to respondent
a Form 12153, Request for a Collection Due Process Hearing
(Request). In his Request, petitioner stated that he had lost
all of the value of the stock from which his tax liability
originated and that the loss was beyond his control because it
resulted from a downturn in the economy. Petitioner also claimed
that his job security was uncertain, that he was in debt, and
that he was a loyal taxpayer. Petitioner asked respondent not to
place a lien on his property because of his precarious financial
condition.
By letter dated November 10, 2004, respondent’s Appeals
Office informed petitioner that his Request had been received and
that a telephone hearing had been scheduled for December 9, 2004.
On November 24, 2004, respondent received a letter from
petitioner requesting a face-to-face hearing. Petitioner
attached to his request a Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals, and
documentation to substantiate the figures on his Form 433-A. On
his Form 433-A, petitioner reported assets of $16,000 ($6,000 in
cash and $10,000 in investments), $18,500 in credit card debt,
and a monthly net income of $2,230.4
4On his Form 433-A, petitioner reported monthly income from
salaries of $6,280 and monthly expenses of $4,050. Petitioner’s
monthly expenses included other expenses of $1,500.
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Last modified: March 27, 2008