Will K. Ng - Page 6

                                        - 6 -                                         
          1993, 1994, and 1995 of $29,347.57, $33,763.22 and $30,195.96,              
          respectively.                                                               
               On March 24, 2004, petitioner made payments totaling $20,000           
          toward his 2002 tax liability.                                              
               In a letter dated July 7, 2004, respondent sent petitioner a           
          Final Notice--Notice of Intent to Levy and Notice of Your Right             
          to a Hearing (notice of intent to levy) for the outstanding 1994,           
          1995, and 2002 liabilities.  The notice of intent to levy showed            
          a total of $121,218.36 in unpaid taxes, interest, and penalties.            
               On July 14, 2004, petitioner paid respondent a total of                
          $56,731.05, satisfying his 2002 tax liability.                              
               On July 15, 2004, respondent sent petitioner a Notice of               
          Federal Tax Lien Filing and Your Right to a Hearing Under IRC               
          6320 (NFTL).  On August 11, 2004, petitioner filed a Form 12153,            
          Request for a Collection Due Process Hearing, with regard to the            
          NFTL.                                                                       
               Appeals Officer Lawrence Dorr was assigned to petitioner’s             
          case.  Petitioner’s hearing consisted of an in-person meeting               
          with Officer Dorr on January 19, 2005, and subsequent                       
          correspondence.  During the hearing, petitioner raised the                  
          argument that although he had violated the literal terms of the             
          OIC by failing to timely pay his 2002 income tax liability, his             
          breach was not “material” and that respondent therefore should              
          not have declared him in default on the OIC.  Officer Dorr did              






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011