- 5 -
years.3 After March 2002, petitioner stopped making installment
payments.
Collection Activity
On April 22, 2003, respondent sent petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 with respect to petitioner’s Federal income tax liabilities
for 1987, 1990, 1991, 1997, 1998, 2000, and 2001. The notice
indicated that the total tax petitioner owed for these years was
about $65,231 (exclusive of interest), with about $42,631 of this
amount attributable to 1987, 1990, and 1991.
On April 24, 2003, petitioner sent respondent a Form 12153,
Request for a Collection Due Process Hearing. On the Form 12153,
petitioner disputed his underlying tax liabilities for 1987,
1990, and 1991 on the ground that his liabilities for those years
should have been eliminated by net operating loss carrybacks and
carryforwards from 1988 and 1989. Petitioner complained that the
time for claiming these carrybacks and carryforwards had
“expired” while respondent’s revenue agents had control of his
3 With respect to petitioner’s 1987 year, respondent’s
transcripts of petitioner’s account show installment payments of
$750 each on July 30 and Aug. 30, 2000, Feb. 24, Mar. 8, and June
1, 2001, and Mar. 6, 2002. With respect to petitioner’s 1994
year, respondent’s transcripts of petitioner’s account show 18
installment payments of $750 each (except for one of $726)
between Dec. 1, 1999, and Feb. 5, 2002. With respect to
petitioner’s 1995 year, respondent’s transcripts of petitioner’s
account show seven installment payments of $750 each (except for
one of $708) between June 27, 1999, and Jan. 3, 2002.
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Last modified: May 25, 2011