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deficiency with respect to 1988 and 1989. Petitioner did not
file timely petitions with this Court in response to the notices
of deficiency, and the deficiencies were assessed.
On March 17, 1997, petitioner filed his 1988 and 1989
Federal income tax returns. Respondent abated the assessments
down to the amount shown on petitioner’s returns. Thereafter,
petitioner requested audit consideration, and respondent
initiated an examination of petitioner’s return. During the
examination, the revenue agent proposed additional assessments
for each year, and petitioner signed Forms 4549-CG on June 21,
1999. The Forms 4549-CG show deficiencies of $3,036 and $2,695
for 1988 and 1989, respectively.
Respondent issued a Letter 1058, Final Notice of Intent to
Levy and Notice of Your Right to a Hearing, on June 23, 2005. On
June 24, 2005, respondent’s revenue officer filed an NFTL at the
County Recorder, San Diego, California. On June 29, 2005,
respondent’s revenue officer issued a Letter 3172(DO), Notice of
Federal Tax Lien Filing and Your Right to a Hearing under IRC
6320. Petitioner submitted a Form 12153, Request for a
Collection Due Process Hearing, with respect to both notices.
Respondent consolidated the hearings into one proceeding. In
communications with the Appeals officer, petitioner sought to
challenge the underlying tax liabilities and would not offer any
alternatives to collection. Because petitioner intended to seek
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