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liability for 1996. Additionally, respondent applied “estimated
tax declarations” to petitioner’s outstanding tax liability for
1998 on April 16, 1998, June 16, 1998, September 17, 1998, and
February 20, 1999.
On or about February 24, 2001, respondent filed a Notice of
Federal Tax Lien (tax lien) regarding petitioner’s income tax
liabilities for 1996, 1997, and 1998 at the U.S. District Court
in Boston, Massachusetts. The tax lien listed the following
amounts owed as of the date of the tax lien:
Tax Period Type of Tax Amount Owed
1996 1040 $5,722.77
1997 1040 14,142.02
1998 1040 10,133.70
On March 1, 2001, respondent issued to petitioner a Notice
of Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 (hearing notice) regarding his income tax liabilities for
1996, 1997, and 1998.
Petitioner submitted a Form 12153, Request for a Collection
Due Process Hearing (hearing request), regarding his 1996, 1997,
and 1998 tax years that respondent treated as being timely
submitted. In his explanation of why he did not agree with the
tax lien, petitioner stated:
I had no income for tax years 1996, 1997, 1998 that is
not exempt, eliminated, or excluded from gross income.
I understand that this may conflict with third party
reports which you may have in your files. Further,
whether or not I am required to file a tax return and
pay a tax is a factual matter for a trier of fact to
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Last modified: May 25, 2011