Roland D. Van Fossen - Page 2




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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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