- 3 -
1999 Aug. 15, 2000 Apr. 15, 2003 102,994 47,963 19,208
2000 Aug. 15, 2001 Aug. 28, 2002 151,475 28,949 17,792
Respondent assessed the tax for each year and demanded
payment for the unpaid balances.3 When petitioner failed to pay
the balances, respondent determined that enforced collection
action would be required. On November 12, 2003, respondent
mailed petitioner a Letter 1058, Final Notice of Intent to Levy
and Notice of Your Right to a Hearing for 1997 and 1998, and a
separate such notice for 1999 and 2000.4 According to
respondent’s notices of levy, petitioner’s total unpaid tax
liability, including additions to tax and interest, exceeded
$200,000.5 In response to each notice of levy, petitioner, by
means of a Form 12153, Request For a Collection Due Process
Hearing, timely requested a hearing under section 6330. In his
requests for a hearing, petitioner claimed: (1) He was entitled
to abatement of the “penalties”6 assessed against him because he
3Respondent assessed $1,337 of additional tax for 1997 in
May of 2003 and $1,927 of additional tax for 2000 in December of
2003. By the time he filed the petitions, petitioner had paid
approximately $30,700 of his tax liability for the 4 years in
issue.
4On or about Nov. 14, 2003, a Federal tax lien was obtained
on petitioner’s property with respect to all tax years at issue.
Petitioner does not contest the propriety of the tax lien filing.
5The income tax assessments include additions to tax under
sec. 6651(a)(1) and (2) for all tax years at issue and under sec.
6654 for 1997, 1998, and 1999.
6References to penalties in various places in the record
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007