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Lien. The Notice of Federal Tax Lien states that petitioner has
an outstanding Federal income tax liability of $1,688.79 for the
taxable year 1995. The signature block on the Notice of Federal
Tax Lien contains a facsimile signature.
On May 3, 2000, respondent mailed to petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320. On June 2, 2000, petitioner filed with respondent a
Request for a Collection Due Process Hearing that included
allegations challenging the existence and amount of petitioner’s
tax liability for 1995 on the ground that petitioner was not
informed of the statutory provisions imposing liability on him.
Petitioner also argued that the Notice of Federal Tax Lien Filing
was invalid because it did not include an original signature.
On July 10, 2000, Appeals Officer Donna Fisher conducted an
Appeals Office hearing in this matter that petitioner attended.
Prior to the hearing, Appeals Officer Fisher reviewed an
individual master file transcript dated April 4, 2000, and a
computer transcript known as TXMODA dated June 30, 2000,
regarding petitioner’s account for the 1995 taxable year. The
transcripts indicated that respondent made assessments against
petitioner on October 19, 1998, for the tax, addition to tax, and
accuracy-related penalty set forth in the notice of deficiency
dated May 8, 1998, and for statutory interest. In addition, the
transcripts indicated that on October 19 and November 9, 1998,
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