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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2000, and requesting that the notice be withdrawn or that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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Last modified: May 25, 2011