- 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 NextLast modified: November 10, 2007