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The petition in this case was filed in response to a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330 (Notice of Determination). Pursuant to sections
6320(c) and 6330(d), petitioner seeks review of respondent's
filing of a Notice of Federal Tax Lien (NFTL) for his tax
liability for 1998. This case is now before the Court on
respondent’s motion for summary judgment under Rule 121.
Background
At the time the petition in this case was filed, petitioner
resided in San Bruno, California.
Respondent issued to petitioner a Final Notice of Intent to
Levy on June 18, 2002, for his 1998 tax liability. On June 20,
2002, respondent issued to petitioner a Notice of Federal Tax
Lien Filing And Your Right To A Hearing Under IRC 6320 for 1997
and 1998. Petitioner’s Form 12153, Request for a Collection Due
Process Hearing, concerning 1998 was filed July 31, 2002, and was
timely as to the filing of the NFTL but was not timely as to the
proposed levy action.
Petitioner’s hearing was conducted by way of written and
oral communications between the Appeals officer and petitioner’s
representative. Although petitioner’s representative submitted
two versions of Form 433-A, Collection Information Statement for
Wage Earners and Self-Employed Individuals, to the Appeals
officer, in April and October 2003, the representative never
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