Craig H. Bond and Jennifer Bond - Page 2




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                                     Background                                       
               This is an appeal from respondent’s determination to uphold            
          the validity of a notice of Federal tax lien filed with respect             
          to petitioners’ 2001 unpaid income tax liability.  Petitioners              
          resided in Henrietta, New York, when the petition was filed.                
               Petitioners filed their joint Federal income tax return for            
          2001.  Respondent subsequently commenced an examination of                  
          petitioners’ 2001 tax year and determined a deficiency in                   
          petitioners’ income tax and an accuracy-related penalty under               
          section 6662.  On October 27, 2004, respondent mailed petitioners           
          a statutory notice of deficiency.                                           
               Petitioners failed to petition this Court with respect to              
          the October 27, 2004, notice of deficiency.  Consequently,                  
          respondent assessed petitioners’ unpaid 2001 tax liability and              
          issued notice and demand for payment.  Petitioners failed to                
          respond to respondent’s request, and on October 5, 2005,                    
          respondent issued to petitioners a Notice of Federal Tax Lien               
          Filing and Your Right to a Hearing Under I.R.C. 6320.                       
          Petitioners timely submitted a Form 12153, Request for a                    
          Collection Due Process Hearing.                                             
               On December 21, 2005, Appeals Officer Kenneth J. Heidle                
          (Officer Heidle) conducted a conference with Harold Rehm (Mr.               
          Rehm), petitioners’ representative and 2001 tax return preparer.            
          However, because Officer Heidle concluded that Mr. Rehm was not             







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