- 2 - 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 JanuaryPage: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007