- 5 - hearing, petitioner claimed that his liability for his taxable year 1998 was incorrect because, according to petitioner, he made some money in the stock market and later lost everything. Petitioner provided no documents or specific information to establish his claim during the hearing that his liability for his taxable year 1998 was incorrect. During the hearing, petitioner indicated that he did not recall whether he received a notice of deficiency relating to his taxable year 1998. Petitioner further stated that he was unable to pay petitioner’s unpaid liability for 1998. Petitioner acknowledged during the hearing that he had not filed tax returns and indicated that he might need profes- sional help. During the hearing, the settlement officer reminded petitioner that no collection alternatives were available because he had not filed his delinquent tax returns and did not submit the financial information that the settlement officer requested in the April 24, 2006 letter. The settlement officer advised petitioner during the hearing that she intended to issue a notice of determination with respect to petitioner’s unpaid liability for 1998. On June 28, 2006, the Appeals Office issued to petitioner a notice of determination concerning collection action(s) under section 6320 and/or 6330 (notice of determination). That notice stated in pertinent part:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007