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Although petitioner attached a Form W-2, Wage and Tax Statement,
showing that petitioner earned $20,2952 from Viking Freight, the
1997 return reports no income and no tax liability. Because
petitioner did not file a Federal income tax return for 1998 or
1999, respondent prepared substitutes for returns for those years
based on Forms W-2 and other third-party information documents.
Respondent assessed a $500 civil penalty against petitioner
under section 6702 for filing a frivolous tax return for 1997.
Respondent also determined a deficiency in income tax for each of
the years 1997, 1998, and 1999 and issued petitioner separate
notices of deficiency for each year. Petitioner did not petition
the Court in response to any of the notices. Respondent assessed
the tax reflected in the notices of deficiency and, on the same
dates as the assessments were made, issued petitioner statutory
notices of balance due.
After petitioner failed to make payment, respondent issued a
notice of intent to levy.3 Petitioner timely submitted a Form
12153, Request for a Collection Due Process Hearing.
Petitioner’s case was assigned to a settlement officer, who
conducted an administrative hearing with petitioner by
correspondence. The settlement officer considered both the civil
2 All dollar amounts are rounded to the nearest dollar.
3 The notice of intent to levy also included civil penalties
assessed under sec. 6702 for the taxable years 1993 through 1996.
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Last modified: November 10, 2007