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and for 1996, in which respondent informed petitioner that, in
order to contest the proposed lien filings, petitioner must
request a CDP hearing within 30 days.
On September 30, 1999, respondent received from petitioner a
Form 12153, Request for a Collection Due Process Hearing, in
which petitioner requested a CDP hearing with respect to the
above proposed levy and the proposed lien filings.
Sometime after September 30, 1999, respondent denied
petitioner a CDP hearing with respect to the proposed levy, but
respondent granted petitioner a CDP hearing with respect to the
proposed lien filings.
Respondent, however, did grant petitioner an equivalent
hearing under section 301.6330-1T(i), Temporary Proced. & Admin.
Regs., 64 Fed. Reg. 3413 (Jan. 22, 1999), with respect to the
proposed levy.
On August 30, 2000, at the conclusion of the equivalent
hearing, respondent issued to petitioner a decision letter in
which respondent concluded that respondent’s Levy Letter was
properly mailed to petitioner at petitioner’s last known address,
that petitioner’s request for a CDP hearing with regard to the
proposed levy was untimely, and that petitioner was not entitled
to any relief with regard to the proposed levy.
On September 7, 2000, with respect to the proposed lien
filings, respondent issued to petitioner a notice of
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