Richard M. Downing - Page 8
- 8 -
authorizing accountants L. Troy Clayton and Terry L. Roe to
represent petitioner with respect to his 1995 through 2002
Federal income tax. The Form 2848 lists the New Hampshire
address for petitioner and the Idaho address for these
accountants. Pursuant to the terms of the Form 2848, original
notices and other written communications were to be sent to
petitioner and copies to Mr. Clayton.
Notice of Intent To Levy and Notice of Levy
On April 22, 2003, respondent sent to petitioner, by
certified mail to the Idaho address, a final notice of intent to
levy and notice of right to a hearing for taxable years 1995 and
1999. Petitioner did not receive this notice during 2003.
Neither he nor his accountants responded to this notice.
On or about February 20, 2004, respondent mailed a notice of
levy for 1995 and 1999 to Charles Schwab & Co. and received in
response $161, which was applied to petitioner’s 1995 liability.
Notice of Federal Tax Lien Filing
On March 4, 2004, respondent sent to petitioner, by
certified mail to the Idaho address, a notice of Federal tax lien
filing and right to a hearing for taxable years 1995 and 1999.
Petitioner’s Request for Hearing and Second Power of Attorney
By letter dated March 17, 2004, petitioner responded to the
March 4, 2004, notice of Federal tax lien filing and right to a
hearing, requesting a hearing. The letter states: “The taxpayer
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: November 10, 2007