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the IRS District Director in Cincinnati, Ohio.2
Petitioner did not file a petition for redetermination with
the Court within the 90-day period prescribed in section 6213(a).
Consequently, on July 3, 2000, respondent assessed the determined
deficiency and accuracy-related penalty for 1997, as well as
statutory interest. On August 7, 2000, respondent assessed the
determined deficiency and accuracy-related penalty for 1996, as
well as statutory interest. Presumably, respondent also assessed
the determined deficiency and accuracy-related penalty for 1998,
but that year is not part of the present case.
B. Notice of Federal Tax Lien
On March 9, 2001, respondent sent to petitioner, by
certified mail, a Notice of Federal Tax Lien Filing and Your
Right to a Hearing Under IRC 6320 (the notice required by section
6320). The notice required by section 6320 listed petitioner’s
unpaid tax liabilities for 1996 and 1997. Three days later, on
March 12, 2001, respondent filed a Notice of Federal Tax Lien
with the Recorder of Mercer County in Celina, Ohio, with regard
to petitioner’s unpaid tax liabilities for 1996 and 1997. Brenda
McCullough, Acting Technical Support Group Manager responsible
for collection matters, authorized the issuance of the notice
required by section 6320 and the filing of the Notice of Federal
2 The record does not definitively reveal “BL’s” identity.
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