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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:
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Last modified: November 10, 2007