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On April 15, 1999, petitioner filed with respondent a
document purporting to be petitioner’s Federal income tax return
for 1998. This document was not complete and did not reflect
petitioner’s income. On this document, petitioner’s mailing
address was indicated as 3451 Nightflower Lane, Apartment C, Las
Vegas, Nevada 89121 (Nightflower address).
As of May 17, 1999, petitioner’s address was still indicated
in respondent’s computer system as the Desert Inn address.
On May 17, 1999, respondent mailed to petitioner at the
Desert Inn address a Letter 1058, Notice of Intent to Levy and
Notice of * * * [a] Right To a Hearing (Levy Letter) relating to
$122,202 in petitioner’s unpaid Federal income taxes for 1984
through 1987, 1991 through 1993, and 1996, in which respondent
informed petitioner that, in order to contest the proposed levy,
petitioner must request from respondent a Collection Due Process
(CDP) hearing within 30 days of May 17, 1999.
Respondent did not receive a request from petitioner for a
CDP hearing within 30 days of respondent’s mailing of the Levy
Letter.
On each of September 2, 1999, and September 10, 1999,
respondent mailed to petitioner at the Nightflower address a
Letter 3172, Notice of Federal Tax Lien Filing and * * * [a]
Right to a Hearing Under IRC 6320 (Lien Letters), with respect to
petitioner’s unpaid Federal income taxes for 1984 through 1987
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Last modified: May 25, 2011