Fletcher H. Hyler - Page 24

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          payment of the liabilities specified and warned him of the                  
          consequences of doing nothing.                                              
               Petitioner further argues that respondent was required to              
          send to him notice of intent to file the notice of tax lien                 
          before the notice was actually filed, but petitioner is                     
          incorrect.  Section 6320 only requires that notice be sent to the           
          taxpayer within 5 days after the notice of tax lien has been                
               Petitioner argues that respondent violated some procedures             
          set forth in the Fair Debt Collection Practices Act (FDCPA),                
          Pub. L. 95-109, 91 Stat. 874 (1977), 15 U.S.C. sec. 1692 (2000).            
          By its terms, however, that act does not apply to employees of              
          the Government whose collection activities are part of their                
          jobs.  See 15 U.S.C. sec. 1692a(6) (2000).  Congress has amended            
          the Internal Revenue Code to require respondent to observe some             
          FDCPA procedures.  See sec. 6304 as added by RRA 1998, sec. 3466,           
          112 Stat. 768; see also H. Conf. Rept. 105-599, at 291 (1998),              
          1998-3 C.B. 747, 1045.  Petitioner’s reliance upon FDCPA                    
          practices that Congress has not included in the Internal Revenue            
          Code is unavailing.                                                         
               Nor has petitioner convinced us that respondent has deprived           
          him of constitutional due process by a perceived accumulation of            
          procedural mistakes.  As we noted at trial, mistakes have been              
          made by both sides in this dispute.  None of respondent’s                   

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