- 2 - he had received notice of deficiency prior to the assessment of the liabilities in question. Background Respondent issued statutory notices of deficiency to petitioner on November 14, 1996, and April 16, 1998, determining income tax deficiencies and penalties for the 1990, 1991, 1992, and 1993 tax years. Petitioner failed to petition this Court with respect to either notice, and respondent assessed the income tax deficiencies and penalties. On March 2, 1999, respondent sent petitioner a Final Notice--Notice of Intent To Levy and Notice of Your Right to a Hearing. On or about March 8, 1999, respondent filed a Notice of Federal Tax Lien, which was recorded on March 16, 1999. On March 11, 1999, respondent provided to petitioner a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320. On March 17, 1999, respondent received petitioner’s timely Request for a Collection Due Process Hearing. On May 20, 1999, respondent issued a Notice of Determination Concerning Collection Action(s) Under Sections 6320 and/or 6330, approving the lien and levy actions and denying relief to petitioner. Petitioner filed a Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d),1 seeking relief from respondent’s collection activity. Respondent moved to dismiss 1 Section references are to the Internal Revenue Code as amended and in effect for the period under consideration.Page: Previous 1 2 3 4 Next
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