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1992 and 1993 income tax liabilities; and (2) whether petitioner
is liable for a penalty pursuant to section 6673.
Background
At the time he filed the petition, petitioner resided in
Florida.
Petitioner failed to file Federal income tax returns for
1992 and 1993. On March 13, 1995, respondent prepared
substitutes for return for 1992 and 1993. On August 26, 1996,
respondent assessed $15,343 of tax for 1992, $1,626 of tax for
1993, and interest and additions to tax for 1992 and 1993. On
August 1, 2005, respondent issued to petitioner a Final Notice--
Notice of Intent to Levy and Notice of Your Right to a Hearing
regarding petitioner’s outstanding 1992 and 1993 income tax
liabilities.
On August 8, 2005, petitioner sent respondent a Form 12153,
Request for a Collection Due Process Hearing (section 6330
hearing request). Petitioner attached to the Form 12153 several
documents containing frivolous and groundless arguments,
questions, and statements regarding his liability for income
taxes, the legality of imposing income taxes on individuals, and
respondent’s authority to collect income taxes.
Settlement Officer James Feist was assigned to petitioner’s
case. In a letter dated January 20, 2006, Settlement Officer
Feist acknowledged receipt of petitioner’s Form 12153 and other
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Last modified: November 10, 2007