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Petitioner did not remit any payments for the amounts due on
these returns when they were filed.
Respondent assessed the taxes shown on the above returns.
Calculated as of January 1, 2005, petitioner owed in excess of
$773,368 for the tax years 1996-2002, inclusive.
In October 2004, petitioner filed his 2003 individual income
tax return. Withheld taxes for 2003 exceeded total tax by
$8,016. The excess withheld taxes combined with an estimated tax
payment of $15,600 resulted in a $23,616 overpayment of tax for
2003. This overpayment was applied to petitioner’s 1996 unpaid
tax liability.
Respondent sent the following collection notices to
petitioner for unpaid Federal income taxes: Notice of Federal
Tax Lien Filing and Your Right to a Hearing Under IRC 6320, dated
October 2, 2003, for the 1997-2001 tax years; a Final Notice -
Notice of Intent to Levy and Notice of Your Right to a Hearing,
dated February 10, 2004, for 2002; a Final Notice - Notice of
Intent to Levy and Notice of Your Right to a Hearing, dated March
8, 2004, for 1996; and a Notice of Federal Tax Lien Filing and
Your Right to a Hearing Under IRC 6320, dated April 1, 2004, for
1996. (Neither party has explained this 1996 discrepancy.)
Petitioner timely requested a hearing in response to each of
these Notices. On each Form 12153, Request for a Collection Due
Process Hearing, petitioner stated that he was preparing a Form
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Last modified: November 10, 2007