Morris Tabak - Page 4




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               B.  Post-assessment Payments Made by Petitioner                        
               In 2000 and 2001, petitioner made a total of 4 payments in             
          the aggregate amount of $4,953.42 toward his unpaid liability for           
          1997.                                                                       
               In 2001, petitioner made a single payment in the amount of             
          $103 toward his unpaid liability for 1998.                                  
               As of April 20, 2001, the unpaid balance of petitioner’s               
          assessed liability was as follows:                                          
                         Unpaid Balance                                               
                         Year                of Assessment                            
                         1997                  $9,833.66                              
                         1998                  15,768.19                              
                         25,601.85                                                    

               C.  Notice of Federal Tax Lien                                         
               On April 26, 2001, respondent filed a notice of Federal tax            
          lien with the County Clerk of Fort Bend County in Richmond,                 
          Texas, in respect of petitioner’s outstanding tax liabilities for           
          1997 and 1998.  Thereafter, on May 1, 2001, respondent sent                 
          petitioner a Notice of Federal Tax Lien Filing and Your Right to            
          a Hearing Under IRC 6320, which petitioner received no later than           
          May 4, 2001.                                                                
               D.  Petitioner’s Request for a Hearing                                 
               On May 4, 2001, petitioner filed with respondent Form 12153,           
          Request for a Collection Due Process Hearing, in respect of his             
          tax liabilities for 1997 and 1998.  In his request for a hearing,           
          petitioner stated that he did not agree with the filed notice of            





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