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to petitioner’s taxable years 1992 and 1995. That notice stated
in pertinent part:
Your Federal tax is still not paid. We previously
asked you to pay this, but we still haven’t received
your payment. This letter is your notice of our intent
to levy under Internal Revenue Code (IRC) Section 6331
and your right to receive Appeals consideration under
IRC Section 6330.
We may file a Notice of Federal Tax Lien at any
time to protect the government’s interest. A lien is a
public notice to your creditors that the government has
a right to your current assets, including any assets
you acquire after we file the lien.
If you don’t pay the amount you owe, make alterna-
tive arrangements to pay, or request Appeals consider-
ation within 30 days from the date of this letter, we
may take your property, or rights to property, such as
real estate, automobiles, business assets, bank ac-
counts, wages, commissions, and other income. * * *
* * * * * * *
The amount you owe is * * *
Unpaid Amount
Form Tax from Prior Additional
NumberPeriod Notices Penalty & Interest Amount You Owe
1040 12/31/1992 [1]12412.21 [2]3005.76 15417.97
1040 12/31/1995 [1]217010.53 [2]148214.35 365224.88
Total: 380642.85
1The amount shown for each of the years 1992 and 1995 under
the heading “Unpaid Amount from Prior Notices” is the same as the
amount of the balance shown due in Form 4340 with respect to each
of petitioner’s taxable years 1992 and 1995.
2The amount shown for each of the years 1992 and 1995 under
the heading “Additional Penalty & Interest” is the additional
amount of penalties and/or interest for each such year that is not
reflected in Form 4340 with respect to each of petitioner’s
taxable years 1992 and 1995.
In response to the notice of intent to levy, on September 7,
2000, petitioner filed Form 12153, Request for a Collection Due
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Last modified: May 25, 2011