Donald Ertz - Page 7

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          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.                                                      




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