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FINDINGS OF FACT
When the petitions were filed, the Ledfords operated Service
Engineering Trust, an entity located in Colorado Springs,
Colorado, where they resided. The assessments relate to 1993,
1994, and 1995 Federal income taxes.
On April 20, 1999, respondent issued a Notice of Federal Tax
Lien Filing and Your Right to a Hearing Under IRC 6320 (i.e.,
Letter 3172) to each petitioner. On May 19, 1999, petitioners
filed Requests for a Collection Due Process Hearing (i.e., Form
12153) and contended that there was no “valid summary record of
assessment”. In letters dated November 17, 1999, respondent’s
Appeals officer enclosed the respective Certificate of Official
Record and Certificate of Assessments and Payments (i.e., Form
4340) relating to each petitioner and advised petitioners to have
their representative call him “on December 14, 1999 at 09:00 at
303 844-2203. This will be your opportunity for a hearing.” In
a letter dated November 24, 1999, petitioners’ representative
enclosed interrogatories directed to the assessment officer and
wrote: “we are not disputing the taxes. We are questioning the
existence or lack thereof of any assessment.” On December 13,
1999, the Appeals officer left petitioners’ representative a
telephone message and sent him a letter reminding him that the
“hearing is scheduled for December 14, 1999, at 09:00 a.m.” On
December 14, 1999, at approximately 1:10 p.m., petitioners’
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Last modified: May 25, 2011