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president of Witness. He resigned his position as president in
October 1996 but in doing so offered to continue to serve the
company in other capacities.
On August 30, 1999, the Internal Revenue Service (IRS) sent
a Notice CP 2501, Initial Inquiry Letter, requesting additional
information from petitioner about the discrepancy between the
income he reported on his 1997 return and the information that
was reported to the IRS by others, including Witness. Petitioner
complied with this request, and received a letter from the IRS
acknowledging his response. On November 13, 2000, a statutory
notice of deficiency (based on $56,370 of omitted income from
Witness) was sent by certified mail to petitioner at the same
address where respondent had sent the Notice CP 2501 on August
30, 1999 (to which petitioner responded). Petitioner did not
petition the Tax Court with respect to the notice of deficiency.
On June 4, 2002, a Letter 11, Notice of Intent to Levy and
Notice of Your Right to a Hearing, with respect to petitioner's
income tax liability for 1997 was mailed to petitioner.
Petitioner timely submitted a Form 12153, Request for a
Collection Due Process Hearing, with respect to the levy notice.
In connection with the hearing on the proposed levy (levy
hearing) petitioner contended that he did not receive any income
from Witness in 1997. The Appeals employee conducting the levy
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