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file a petition with the Court challenging the notices of
deficiency for 1988 and 1993 through 1995.
B. Collection Procedures
On February 7, 2000, respondent mailed to petitioner a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing
requesting that petitioner pay his delinquent taxes for the years
1987 and 1989 through 1995.6 Two days later, on February 9,
2000, respondent filed a Notice of Federal Tax Lien with Dallas
County in Dallas, Texas, listing petitioner’s tax liabilities for
the taxable years 1993 through 1995.
On March 7, 2000, respondent received from petitioner a Form
12153, Request for a Collection Due Process Hearing, challenging
respondent’s levy notice for the taxable years 1987 and 1989
through 1995. On March 20, 2000, respondent received from
petitioner a second Form 12153, this one challenging respondent’s
lien notice for the taxable years 1993 through 1995. Each of the
Forms 12153 listed petitioner’s address as the DalRich Village
address.
On October 13, 2000, respondent’s Appeals Office issued to
petitioner a Notice of Determination Concerning Collection
Actions Under Section 6320 and 6330 stating that an
administrative hearing was conducted on August 17, 2000, and that
respondent would proceed with collection as set forth in the lien
6 The disputed collection action does not include
petitioner’s tax liability for 1988.
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Last modified: May 25, 2011