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Background
The record reveals or the parties do not dispute the
following:
Petitioner failed to file Federal income tax returns for
1985, 1986, 1987, 1988, 1989, 1990, 1991, and 1992. By three
separate notices of deficiency dated December 8, 1995, respondent
determined these deficiencies in and additions to petitioner’s
tax:
Additions to Tax
Sec. Sec.
Year Deficiency 6651(a)(1) 6654
1985 $37,138 $9,285 $2,128
1986 95,433 23,858 4,619
1987 105,703 26,426 5,708
1988 71,986 17,997 4,601
1989 516,660 129,165 34,941
1990 717,686 179,422 47,254
1991 1,023,198 255,800 58,855
1992 1,307,844 326,961 57,040
Petitioner received the notices of deficiency but did not
petition the Tax Court with respect thereto.
On November 2, 2004, respondent mailed petitioner a Notice
of Intent to Levy and Notice of Your Right to a Hearing for
taxable years 1985 through 1992. This notice indicated that
petitioner’s unpaid liability, including interest, totaled $14.8
million. In response to this notice, on November 23, 2004,
petitioner submitted a Form 12153, Request for a Collection Due
Process Hearing, challenging the proposed levy on grounds of
doubt as to liability and doubt as to collectibility. On January
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Last modified: November 10, 2007