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taxable years 1987 and 1988. Respondent mailed statutory notices
of deficiency for 1987 and 1988 to petitioner at his last known
address on March 9, 1994. Petitioner did not request judicial
review of these deficiencies.
On February 5, 2002, respondent issued and mailed a Final
Notice - Notice of Intent to Levy and Notice of your Right to a
Hearing regarding taxable years 1987 and 1988 to petitioner.
This notice sought to collect taxes and additions to tax in the
amounts of $9,973.28 and $12,467.41, respectively, for 1987 and
$11,091.20 and $11,194.60, respectively, for 1988. Petitioner
timely requested a hearing regarding the proposed collection
action. Petitioner received a hearing consisting of telephone
conferences on November 25, 2002, and March 25, 2003. The
discussions primarily centered around an offer-in-compromise
(OIC), as the Appeals officer advised that petitioner’s
underlying tax liabilities would not be considered.
After several attempted submissions, on April 23, 2003,
petitioner finally made a complete and reviewable offer based on
doubt as to collectibility. The Appeals officer forwarded the
OIC to respondent’s offer specialist for consideration. The
offer specialist reviewed the offer and made repeated requests of
petitioner for additional information. Petitioner failed to
respond to any of the requests, so respondent’s offer specialist
returned the OIC to the Appeals officer. The Appeals officer
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