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