Warren D. Ward - Page 4




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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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