- 2 - 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.”Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011