- 4 -
hearing, but petitioner insisted that his rights were being
violated by his not being allowed to tape-record the hearing.
Petitioner never participated in a hearing, and an Appeals
officer subsequently made a determination. Respondent issued a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (notice of determination) dated October
23, 2003, for petitioner’s year 2000 income tax.
Because petitioner did not timely request a hearing for
1997, 1998, and 1999, respondent granted petitioner an equivalent
hearing for those years. Petitioner did not cooperate in
scheduling or participating in an equivalent hearing. Respondent
issued a Decision Letter Concerning Equivalent Hearing Under
Section 6320 and/or 6330 of the Internal Revenue Code (decision
letter) for civil penalties2 for years 1997, 1998, and 1999, and
the same type of letter, but relating to income taxes, for 1997
and 1998, both letters being dated October 23, 2003. Petitioner
did not include in the record a notice of determination or
equivalent hearing letter, and respondent’s administrative file
contains neither a notice of determination nor an equivalent
hearing letter, concerning income taxes for 1999. Respondent
2The decision letters in the record do not indicate the
types of penalties covered, and explanations were not attached
thereto. We recognize that this Court lacks jurisdiction with
respect to frivolous return penalties. See Van Es v.
Commissioner, 115 T.C. 324, 329 (2000). However, ascertaining
the substance of the penalties is not necessary, since other
requirements for our jurisdiction are lacking for each tax year.
See discussion infra.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011