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respect to petitioner’s taxable years 1993, 1994, and 1995. That
notice stated, inter alia, “We have made a demand for payment of
this liability, but it remains unpaid.”
On September 22, 2000, respondent issued to petitioner a
notice informing him that respondent had filed a Federal tax lien
with respect to his taxable years 1993, 1994, and 1995 and that
he had a right to a hearing (Appeals Office hearing) with respon-
dent’s Appeals Office with respect to that lien.
On October 19, 2000, petitioner filed Form 12153, Request
for a Collection Due Process Hearing (Form 12153). Petitioner
indicated in that form that he did not agree with the filing by
respondent of a Federal tax lien with respect to his taxable
years 1993, 1994, and 1995. In support of that position, peti-
tioner stated in Form 12153 that his “Tax liability is yet to be
established-concerning my diplomatic status / a greencard holder
who stayed less than 31 days in the US. (2) Other matters faxed
to IRS officer.”
On November 29, 2001, respondent’s Appeals Office held an
Appeals Office hearing with petitioner. On December 27, 2001,
the Appeals Office mailed to petitioner a notice of determination
with respect to his taxable years 1993, 1994, and 1995. The
notice stated in pertinent part:
Applicable law and administrative procedures
With the best information available, the requirements
of various applicable laws or administrative procedures
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Last modified: May 25, 2011