- 3 -
B. Respondent’s Notice of Federal Tax Lien
On or shortly after May 2, 2001, respondent filed a notice
of Federal tax lien with the County Recorder for San Diego
County, San Diego, California. See sec. 6323. Thereafter, on
May 7, 2001, respondent mailed to petitioners a Notice Of Federal
Tax Lien Filing And Your Right To A Hearing Under IRC 6320 (the
notice required by section 6320(a)) concerning their unpaid tax
liability for the taxable year 1997.2 The notice required by
section 6320(a) was sent to petitioners at their last known
address, see sec. 6320(a)(2)(C), and was received by them no
later than May 11, 2001.
C. Petitioners’ Request for an Administrative Hearing
On or shortly after May 11, 2001, petitioners sent to the
Internal Revenue Service Office of Appeals (Appeals Office) Form
12153, Request for a Collection Due Process Hearing, concerning
their unpaid tax liability for the taxable year 1997
(petitioners’ request for an administrative hearing). Petitioners
filed their request for an administrative hearing in respect of
both the notice of intent to levy and the notice required by
section 6320(a).
2 Both the notice of Federal tax lien and the notice
required by sec. 6320(a) listed petitioners’ unpaid tax liability
for 1997 as $1,916.23.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011