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On December 15, 2004, after the parties had agreed to a
settlement of all issues, we entered decisions in the above four
dockets in which the parties stipulated deficiencies in
petitioner’s Federal income taxes for 1997, 1998, 1999, and 2000
of $6,085, $4,986, $4,234, and $1,166, respectively. The parties
also stipulated that petitioner had fully paid the tax deficiency
for 2000.
On June 23, 2005, respondent mailed to petitioner a notice
of levy relating to the above Federal income tax deficiencies for
1997, 1998, 1999, and 2001.
On July 19, 2005, petitioner mailed to respondent a written
request for a section 6330 Appeals Office hearing relating to
respondent’s June 23, 2005, levy notice. In petitioner’s written
Appeals Office hearing request, petitioner’s only request was
that he be allowed to pay his above Federal income tax
deficiencies in installments.
On February 14, 2006, petitioner’s attorney held a face-to-
face hearing with respondent’s Appeals officer. At the hearing,
petitioner’s attorney’s only request was that petitioner be
allowed to enter into an installment agreement.
As of the February 14, 2006, hearing date, petitioner had
not filed his Federal income tax return for 2004.
On March 15, 2006, respondent’s Appeals Office mailed to
petitioner an adverse notice of determination sustaining
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