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