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Background
At the time he filed the petition, petitioner resided in
Beverly Hills, California.
On January 11, 1995, respondent mailed petitioner a notice
of deficiency determining deficiencies and additions to tax for
1989 and 1990. On September 22, 2003, respondent mailed
petitioner a notice of deficiency determining a deficiency and
additions to tax for 1998. The record does not establish that
petitioner received either notice of deficiency.
On June 29, 2001, petitioner filed a petition pursuant to
chapter 13 of the U.S. Bankruptcy Code, 11 U.S.C. ch. 13, in the
U.S. Bankruptcy Court for the Central District of California.
In the bankruptcy case, respondent filed a proof of claim and
multiple amended proofs of claim against petitioner regarding
petitioner’s assessed income tax liabilities for 1989, 1990, and
1998. On May 26, 2004, petitioner’s bankruptcy case was
dismissed.
On December 30, 2004, respondent sent petitioner a Final
Notice-–Notice of Intent to Levy and Notice of Your Right to a
Hearing regarding petitioner’s outstanding 1989, 1990, and 1998
income tax liabilities. On January 18, 2005, petitioner sent
respondent a Form 12153, Request for a Collection Due Process
Hearing (hearing request). Petitioner attached to the hearing
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Last modified: November 10, 2007