Joseph E. Lewis - Page 4

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          to levy on petitioner’s property to collect the unpaid liability            
          for tax year 2002.                                                          
               Thereafter, petitioner timely submitted Form 12153, Request            
          for a Collection Due Process Hearing, on June 15, 2005.  In his             
          Form 12153, petitioner again requested an abatement of the late             
          filing and late payment additions to tax assessed for tax year              
          2002.  Petitioner continued to argue that his late filing be                
          excused because of his accountant’s illness.                                
               Petitioner’s case was then assigned to a settlement officer            
          for a collection review hearing.  The settlement officer reviewed           
          the administrative file and determined that petitioner’s request            
          for an abatement of the late filing and late payment additions to           
          tax had already been considered by Appeals.  Thus, the settlement           
          officer determined that petitioner’s underlying liability could             
          not be raised properly again in his collection review hearing.              
          Petitioner did not raise any additional issues with respect to              
          the levy notice.                                                            
               On March 3, 2006, respondent issued to petitioner a Notice             
          of Determination Concerning Collection Action(s) under Section              
          6320 and/or 6330.  In response to the notice of determination,              
          petitioner filed a petition with this Court on March 30, 2006.              
          The only question raised in the petition is whether there is                

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