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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Last modified: November 10, 2007