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On April 10, 2000, respondent filed a Notice of Federal Tax
Lien equal to the amount of taxes and penalties assessed by
respondent with respect to petitioner’s 1996 and 1997 taxable
years.
On April 13, 2000, respondent issued to petitioner a Notice
Of Federal Tax Lien Filing And Your Right To A Hearing Under IRC
6320 with respect to petitioner’s 1996 and 1997 taxable years.
On or about May 11, 2000, petitioner timely filed a Form
12153, Request For A Collection Due Process Hearing (Appeals
Office hearing request), in response to the notice of lien.
On October 25, 2000, in response to petitioner’s Appeals
Office hearing request, an Appeals officer sent a letter to
petitioner in which he provided additional information regarding
the validity of the tax and penalty assessments against
petitioner. The Appeals officer informed petitioner that the
statutory notices of deficiency were sent to his last known
address, that he failed to act upon the statutory notices, and
therefore that he was precluded from further challenging the
underlying tax liabilities. The Appeals officer also informed
petitioner that he would schedule an Appeals Office hearing.
On January 12, 2001, the Appeals officer conducted the
Appeals Office hearing with petitioner and his representative at
the Las Vegas office of the Internal Revenue Service. At the
hearing, the Appeals officer provided petitioner with two Forms
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Last modified: May 25, 2011