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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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Last modified: November 10, 2007