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On or about November 19, 1999, respondent mailed to
petitioner copies of Forms 668(Y)(c), Notices of Federal Tax
Liens (lien filings), that respondent, on November 19, 1999, had
filed in various counties in Oklahoma with respect to
petitioner’s above unpaid $472,532 tax liability for 1980.
On December 22, 1999, petitioner requested in writing from
respondent’s Appeals Office a collection hearing under section
6320 seeking release of respondent’s lien filings relating to
petitioner.
In petitioner’s request for a collection hearing, petitioner
asserted only that the period of limitations on collection under
section 6502 of petitioner’s unpaid tax liability for 1980 had
expired and therefore that respondent’s lien filings with regard
thereto were untimely and improper. Petitioner did not indicate
any other basis for his challenge to the appropriateness of
respondent’s lien filings. Petitioner did not allege hardship,
and petitioner did not offer any alternative to the lien filings.
On January 26, 2000, in United States v. Magana, supra, the
District Court granted the United States’ motion for summary
judgment, and on February 22, 2000, the District Court entered a
judgment against petitioner in favor of the United States in the
amount of $472,532 with respect to petitioner’s unpaid tax
liability for 1980.
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Last modified: May 25, 2011