- 4 - 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Vegas, Nevada, acknowledging receipt of the notice of deficiency dated May 26, 2000, and requesting that the notice be withdrawn or that petitioners be granted an Appeals Office hearing.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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011