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to levy under Internal Revenue Code (IRC) Section 6331
and your right to receive Appeals consideration under
IRC Section 6330.
We may file a Notice of Federal Tax Lien at any
time to protect the government’s interest. A lien is a
public notice to your creditors that the government has
a right to your current assets, including any assets
you acquire after we file the lien.
If you don’t pay the amount you owe, make alterna-
tive arrangements to pay, or request Appeals consider-
ation within 30 days from the date of this letter, we
may take your property, or rights to property, such as
real estate, automobiles, business assets, bank ac-
counts, wages, commissions, and other income. * * *
* * * The amount you owe is:
Form Tax Unpaid Amount Additional
NumberPeriodfrom Prior NoticesPenalty & Interest AMOUNT YOU OWE
1040 1987 [1]$8636.64 [2]$5082.64 $13719.28
* * * * * * *
1040 1990 [1]$1780.25 [2]$1078.73 $2858.98
1The amount shown for each of the years 1987 and
1990 under the heading “Unpaid Amount from Prior No-
tices” is the same as the amount of the balance shown
due in Form 4340 with respect to each such year.
2The amount shown for each of the years 1987 and
1990 under the heading “Additional Penalty & Interest”
is the additional amount of penalties and/or interest
for each such year that is not reflected in Form 4340
with respect to each such year.
In response to the notice of intent to levy, on February 24,
1999, petitioner filed Form 12153, Request For a Collection Due
Process Hearing (Form 12153), and requested a hearing with the
IRS Appeals Office (Appeals Office).
Sometime after February 24, 1999, the Appeals officer
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