- 4 -
On June 27, 2003, respondent received petitioner’s Form 1040
for 1997, reporting a tax liability of $2,069. He did not make
any estimated payments for 1997.
On July 28, 2003, the second offer-in-compromise was
returned because petitioner failed to file a Form 1040 for 1997.
Although respondent received the Form 1040 for 1997 on June 27,
2003, it was not processed until August 18, 2003. On August 18,
2003, respondent assessed the tax liability including penalties
and interest for 1997.
On November 25, 2003, petitioner submitted a third Form 656
with a completed Form 433-A (third offer-in-compromise). The
third offer-in-compromise was rejected because the amount offered
was less than the reasonable collection potential.3
On October 13, 2004, respondent mailed petitioner a Notice
of Federal Tax Lien Filing and Notice of Your Right to a Hearing
Under IRC 6320 (notice of Federal tax lien) for the years at
issue. The notice of Federal tax lien advised petitioner he was
entitled to request a hearing to appeal the collection action and
to discuss optional payment methods. On November 15, 2004,
petitioner submitted Form 12153, Request for a Collection Due
Process Hearing. In his request, petitioner asserted he earned
3 Petitioner was mailed his last rejection letter on Dec.
22, 2004, which gave him 30 days to respond and/or appeal. He
failed to timely file an appeal, and his offer-in-compromise was
closed Jan. 21, 2005.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: November 10, 2007