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address: Post Office Box 1465, Rolla, Missouri, 65401. The
aforementioned Liberty, Missouri, address is the same address
stated on petitioner’s Federal income tax returns for taxable
years 1999 and 2000.
Petitioner failed to file a petition to this Court in
response to the notice of deficiency. Accordingly, respondent
assessed the deficiencies determined for taxable years 1999 and
2000, together with the penalties and interest applicable
thereon, on May 26, 2006.
On July 9, 2004, respondent mailed a Notice of Federal Tax
Lien Filing and Your Right to a Hearing Under IRC 6320 (CDP
Notice) that informed petitioner that a Notice of Federal Tax
Lien had been filed because there were unpaid tax liabilities for
taxable years 1999 and 2000, in the amounts of $7,114.94 and
$32,851.20, respectively. The CDP Notice informed petitioner of
his right to a hearing to appeal the collection action and to
discuss payment method options. Publication 1660, Collection
Appeal Rights, together with Form 12153, Request for a Collection
Due Process Hearing, Form 12153 was enclosed with the CDP Notice.
Petitioner timely mailed a Form 12153. Petitioner’s case
was then referred to the Internal Revenue Service (IRS) Appeals
Office in Kansas City and assigned to James C. Callanan. The
Appeals officer (Mr. Callanan) mailed an acknowledgement letter
to petitioner’s representative, Leonard G. Goldammer (Mr.
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Last modified: November 10, 2007