Harold E. Call - Page 20

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               On reply brief, petitioner expresses his position on this              
          issue as follows:                                                           
                    Two Notices of Federal Tax Lien were filed with                   
               the Clark County Recorder in March of 2003, for tax                    
               years 1998 and 1999.  Petitioner was not notified of                   
               these filings within five days as required by law, and                 
               Internal Revenue Regulations.  Respondent claimed                      
               during the inquisition in Tax Court that notification                  
               was sent to Petitioner.  According to normal procedures                
               such notices are sent Certified Mail and the signed                    
               delivery receipt is retained by the sender.  To date,                  
               no such evidence of delivery has been produced by                      
               Respondent.  Petitioner was made aware of the filing of                
               the notices by an on-line credit watch agency and filed                
               a request for Collection Due Process Hearing on                        
               April 16, 2003.  Petitioner did not obtain copies of                   
               the Notices of Federal Tax Lien until October 30, 2004                 
               when Petitioner went to the Clark County Recorder’s                    
               office in person and requested them. * * *                             
          Petitioner attached to his reply brief copies of the notices of             
          tax lien, prepared and signed by the IRS on March 5, 2003, and a            
          copy of his order receipt for copies of these notices from the              
          Clark County Recorder, dated October 30, 2003.                              
               The Forms 4340 show March 7, 2003, as the date of the                  
          Federal tax liens.  The notice of determination similarly                   
          references March 7, 2003, as the “Date of CDP Notice” and                   
          March 26, 2003, as the “Date Form 12153 Received”.  As previously           
          noted, petitioner’s Form 12153 was submitted on April 16, 2003,             
          with a cover letter indicating that he had sent an earlier March            
          26, 2003, letter pertaining to respondent’s collection                      
          activities, to which he had received no response.                           







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