- 7 - the deficiencies in tax and the section 6621(c) interest as a computational adjustment, no notices of deficiency were issued. On March 7, 2002, respondent issued petitioner a Final Notice--Notice of Intent to Levy and Notice of Your Right to a Hearing (final notice). In addition to petitioner’s outstanding tax liabilities for 1982 through 1988, the final notice included an unpaid amount of $59 from 1993 and interest of $164 and $692 for 1993 and 1997, respectively.7 The final notice indicated that, as of April 6, 2002, petitioner owed $213,258, inclusive of interest. On March 18, 2002, petitioner submitted a Form 12153, Request for a Collection Due Process Hearing. Petitioner indicated that he would be pursuing an offer-in-compromise based alternatively on doubt as to collectibility with special circumstances or effective tax administration. Petitioner also argued that, because he had not had a previous opportunity to dispute the imposition of section 6621(c) interest, it was a proper subject for review in the section 6330 hearing. Petitioner’s case was assigned to Settlement Officer Linda Cochran (Ms. Cochran). Ms. Cochran initially scheduled a telephone section 6330 hearing on April 6, 2004. Petitioner’s representative, Terri A. Merriam (Ms. Merriam), requested that 7 Details regarding petitioner’s 1993 and 1997 tax years are not in the record.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011