- 11 -
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
pursued.
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011