- 2 -
Background
This is an appeal from respondent’s determination upholding
the proposed use of a levy to collect petitioner’s unpaid Federal
income tax liability for 2002. Petitioner resided in California
when the petition was filed.
Petitioner failed to file a Federal income tax return for
2002. On July 27, 2004, respondent mailed a notice of deficiency
for 2002 to petitioner. On October 22, 2004, the Court received
a letter from petitioner that was filed as petitioner’s imperfect
petition at docket No. 20485-04. By order dated October 27,
2004, the Court directed petitioner to file a proper amended
petition and pay the Court’s filing fee on or before December 13,
2004. Petitioner failed to do so. By order dated February 8,
2005, the Court dismissed petitioner’s case at docket No. 20485-
04 for lack of jurisdiction on the grounds that petitioner failed
to file a proper amended petition or pay the filing fee as
ordered.
On July 11, 2005, respondent assessed the 2002 income tax
deficiency, interest, and additions to tax for late filing and
failure to pay and mailed a notice of balance due to petitioner.
On November 12, 2005, respondent sent petitioner a Final Notice
of Intent To Levy and Notice of Your Right to a Hearing for the
year at issue. Petitioner timely submitted a Form 12153, Request
for a Collection Due Process Hearing. In his request, petitioner
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: March 27, 2008