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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.
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Last modified: May 25, 2011