- 2 - abused its discretion in determining to proceed with collection of petitioner’s tax liability for taxable year 2002 by levy. Background At the time of filing the petition in the instant case, petitioner resided in Farmerville, Louisiana. Petitioner failed to file an income tax return for taxable year 2002. On November 18, 2004, respondent sent a notice of deficiency to petitioner at his last known address, which is the same address petitioner listed on his petition in the instant case. Petitioner did not petition this Court for a redetermination of the deficiency for taxable year 2002. On October 7, 2005, respondent sent petitioner a Letter 1058, Notice of Intent to Levy and Your Right to a Hearing. On November 3, 2005, petitioner sent respondent a Form 12153, Request for a Collection Due Process Hearing, containing frivolous arguments.2 By letter dated January 24, 2006, Settlement Officer Suzanne Magee (Mrs. Magee) advised petitioner that his hearing request had been assigned to her, the arguments raised in the hearing request are ones consistently held to be frivolous, and he would 2We note that although the Form 12153 lists as the taxable periods 1998 through 2004 and indicates disagreement with both a lien and a levy, the Notice of Determination relevant to the instant case sustains only a levy for taxable year 2002.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011