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the filing of a notice of federal tax lien (NFTL) was
appropriate.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Bell Gardens, California, at the time their petition was filed.
On August 18, 1999, respondent issued a notice of deficiency
to petitioners determining a deficiency in Federal income tax and
an accuracy-related penalty for the taxable year 1996.
Petitioners filed a petition with this Court in response to the
notice of deficiency. However, petitioners’ case was ultimately
dismissed by the Court for lack of jurisdiction on the ground
that the petition was not timely filed. Petitioners’ 1998 return
was also audited, but they consented to the assessment of a tax
deficiency for that year.
On December 12, 2001, respondent sent to petitioners a
Notice of Federal Tax Lien Filing and Your Right to a Hearing
Under IRC 6320 for their taxable years 1996 and 1998. On January
18, 2002, petitioners requested a section 6330 hearing, stating
that they objected to the filed NFTL because “they never received
an audit notice[,] * * * did not receive a notice of deficiency
and would like an opportunity to dispute the tax liability.”
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Last modified: May 25, 2011