Fletcher H. Hyler - Page 11

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               Please have the completed Collection Information                       
               Statement and verification in my office no later than                  
               May 15, 2000.  If you have any concerns or questions,                  
               you can reach me at the telephone number listed above.                 
               I am required to advise you that failure to provide the                
               above information by the May 15, 2000 [sic] may result                 
               in enforcement action such as, issuance of Final                       
               Notice, Issuance of Notice of Levy, serving summons,                   
               filing Notice of Federal Tax Lien.  Once again do not                  
               hesitate to call.  Thank you.                                          
               Stone never sent to Rosado the information that he had                 
          requested in the April 19, 2000, letter.  Stone did, however,               
          send copies of the letter to petitioner and to Sayers.                      
               Sayers wrote to Rosado requesting that collection action be            
          halted until petitioner’s lawsuit against the Government for                
          damages was resolved.  Rosado received that letter on May 11,               
          2000, and sought legal advice from IRS counsel regarding whether            
          to proceed with collection while the lawsuit was pending.  On               
          June 5, 2000, IRS counsel advised him that collection could be              
               On June 13, 2000, the IRS sent a Notice of Federal Tax Lien            
          to the County Recorder in San Mateo, California, for filing,                
          indicating that petitioner had unpaid Federal income tax                    
          liabilities for 1993, 1995, and 1997.  On June 16, 2000, the IRS            
          sent to petitioner a Notice of Tax Lien Filing and Your Right to            
          a Hearing Under I.R.C. 6320 (Notice) for those years.  The notice           
          of lien was recorded in San Mateo County on June 21, 2000.  On              
          July 20, 2000, petitioner’s counsel timely filed a request under            
          section 6320 for a hearing.                                                 

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Last modified: May 25, 2011