Charles G. and Daphne C. M. Hall - Page 4




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               By letter dated June 26, 2000, petitioners wrote to                    
          respondent’s District Director in Las Vegas, Nevada,                        
          acknowledging receipt of the notice of deficiency dated May 26,             
          2000, and requesting that the notice be withdrawn or that                   
          petitioners be granted an Appeals Office hearing.  Petitioners              
          did not file a petition with the Court challenging the notice of            
          deficiency.  Accordingly, on October 9, 2000, respondent assessed           
          the determined deficiency and accuracy-related penalty, as well             
          as statutory interest.  On that same day, respondent sent                   
          petitioners a notice of balance due, informing petitioners that             
          they had a liability for 1998 and requesting that they pay it.              
          Petitioners failed to do so.                                                
               C.  Respondent’s Final Notice and Petitioners’ Response                
               On February 26, 2001, respondent sent petitioners a Notice             
          of Federal Tax Lien Filing and Your Right to a Hearing Under IRC            
          6320 (lien notice).  The lien notice was issued in respect of               
          petitioners’ outstanding tax liability for 1998.                            
               On March 13, 2001, petitioners submitted to respondent a               
          Form 12153, Request for a Collection Due Process Hearing.                   
          Petitioners’ request stated that they were challenging the                  
          validity of the assessments for 1998 on the grounds there is no             
          statute imposing tax liability upon them and they were not served           
          with a valid notice and demand for payment.                                 








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