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interest) against petitioner.
On August 28, 2000, respondent filed with the Emery County
Recorder in Castledale, Utah, a Form 668(Y)(c), Notice of Federal
Tax Lien, which disclosed that petitioner had an outstanding
Federal income tax liability of $6,937.87 for 1993. Respondent
timely issued to petitioner a Notice of Federal Tax Lien Filing
and Your Right to a Hearing Under IRC 6320. On September 14,
2000, petitioner filed with respondent a Request for a Collection
Due Process Hearing, Form 12153, that included allegations
challenging the existence and amount of his tax liability for
1993.
On January 17, 2001, the Internal Revenue Service Office of
Appeals in Salt Lake City conducted an administrative hearing
that petitioner attended. On January 22, 2001, Appeals Officer
Robert White wrote a letter to petitioner stating, in part, that
he would recommend that the assessment made against petitioner
for 1993 be abated. However, the Appeals officer’s
recommendation to abate the assessment was ultimately rejected by
his supervisor.
By notice of determination dated March 15, 2001, respondent
informed petitioner that the notice of lien filed against him
would not be withdrawn because petitioner failed to show that he
had sufficient basis in the S corporation to cover the loss
claimed on his 1993 return.
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