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2. Letter CP-501: Sent on or about December 28, 1998,
which contained tax liability information and contact telephone
numbers.
3. Letters CP-503: Sent on or about February 1, 1999, and
October 28, 2002, which contained tax liability information and
contact telephone numbers.
4. Letters CP-504: Sent on or about March 8, 1999, April
12, 1999, September 4, 2000, and July 7, 2003, which contained
tax liability information and contact telephone numbers.
5. Letter 3174: Sent on or about August 29, 2003, by
Internal Revenue Officer Beth McCullough advising that if the
1991 tax balance due were not paid by September 12, 2003, an NFTL
would be filed.
6. Letter 3172: Sent on August 4, 2004, by Revenue Officer
McCullough notifying of the filing of an NFTL for petitioner’s
1991 tax liability.
Discussion
Petitioner, who had practiced law in Mississippi for 43
years, represents himself in this proceeding where, for various
reasons, he contends there was an abuse of discretion in
respondent’s filing of an NFTL. On several occasions, petitioner
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