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$10,500 toward petitioner’s then-outstanding 1997 liability, and
$750 toward petitioner’s 1998 liability.
Petitioner’s Section 6330 Hearing
On January 12, 2004, respondent issued to petitioner a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing with respect to petitioner’s unpaid income tax
liabilities for 1994, 1995, 1996, 1998, and 1999 (the years at
issue). On February 10, 2004, petitioner sent to respondent a
Form 12153, Request for a Collection Due Process Hearing. In the
Form 12153, petitioner stated that he “does not agree with the
notice of intent to levy in this case for the simple reason that
the taxpayer does not owe the tax stated in the notice.”
Petitioner’s section 6330 hearing was assigned to Settlement
Officer Greg Clark (Settlement Officer Clark). Petitioner’s
section 6330 hearing consisted of telephone calls and
correspondence between Settlement Officer Clark and petitioner’s
representative and attorney herein, William D. Hartsock.
Petitioner raised three issues during the section 6330
hearing. First, petitioner argued that respondent erroneously
applied payments petitioner made pursuant to an alleged
installment agreement to petitioner’s 1985 tax liability because
the alleged installment agreement required that respondent apply
petitioner’s payments to the years at issue. Second, petitioner
claimed that respondent should have applied alleged overpayments
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Last modified: November 10, 2007