Wayne Smith - Page 4




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          Filing of Federal Income Tax Returns                                        
               Petitioner delinquently filed his Federal income tax return            
          for taxable year 2000 on October 22, 2002.  On his 2000 return,             
          he reported tax in the amount of $13,825, less withholding                  
          credits of $12,502.  He did not remit the $1,323 owed when he               
          filed his return.  Petitioner later made three payments, totaling           
          $557, towards the amount owed for 2000.                                     
               Petitioner delinquently filed his Federal income tax return            
          for taxable year 2001 on January 28, 2003.  On his 2001 return,             
          he reported tax in the amount of $22,511, less withholding                  
          credits of $5,099.  He did not remit the $17,412 owed when he               
          filed his return.                                                           
               Petitioner delinquently filed his 2002 Federal income tax              
          return on May 1, 2003.  On his 2002 return, he reported tax in              
          the amount of $6,227, less withholding credits of $1,700.  He did           
          not remit the $4,672 owed when he filed his return.                         
          Request for Collections Due Process Hearing                                 
               On August 7, 2004, respondent mailed to petitioner a Final             
          Notice of Intent to Levy and Notice of Your Right to a Hearing              
          Under Section 6330/6331, which stated that respondent intended to           
          levy on petitioner’s IRA account in 30 days.  In response,                  
          petitioner timely filed a request for a collection due process              
          (CDP) hearing with respondent’s Appeals Office.  Petitioner’s               
          request for a hearing indicated his disagreement with                       







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