William J. Brumback - Page 2




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                                     Background                                       
               Petitioner submitted to the Internal Revenue Service a Form            
          1040, U.S. Individual Income Tax Return, for 2001 listing only              
          zeros; i.e., listing zero income and zero tax due.                          
               Respondent mailed petitioner a statutory notice of                     
          deficiency for 2001.  Petitioner received the notice of                     
          deficiency for 2001.  Petitioner, however, did not petition the             
          Court regarding the notice of deficiency for 2001.                          
               On July 30, 2004, respondent sent petitioner a Notice of               
          Federal Tax Lien Filing and Your Right to a Hearing (NFTL) with             
          respect to 2001.  The NFTL listed $33,108.45 of tax owed for                
          2001.  The NFTL also listed section 6702 frivolous return                   
          penalties owed for 2000, 2001, and 2002.                                    
               On or about August 14, 2004, petitioner sent respondent a              
          Form 12153, Request for a Collection Due Process Hearing (hearing           
          request).  Attached to the hearing request, petitioner wrote that           
          there were irregularities, errors and/or defects in the:                    
          Accounting records of the Internal Revenue Service, record of               
          assessment, summary record of assessment, verification and                  
          validity of his tax liability, and returns prepared for or                  
          executed for him.  Petitioner did not propose any collection                
          alternatives.                                                               
               On October 29, 2004, Settlement Officer Wendy Clinger sent             
          petitioner a letter advising him he would not receive a face-to-            







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