Paul Everman - Page 4

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          Tax Lien.3  At that time, Ms. McCullough was classified as a GS-            
          14 employee.  Petitioner received the notice required by section            
          6320.                                                                       
               C.  Final Notice of Levy                                               
               On May 7, 2001, respondent mailed to petitioner, by                    
          certified mail, a Final Notice–Notice of Intent to Levy and                 
          Notice of Your Right to a Hearing (final notice of intent to                
          levy) under section 6330 in respect of petitioner’s unpaid tax              
          liabilities for 1996 and 1997.  The final notice of intent to               
          levy, which was not signed, was issued by Revenue Officer John              
          Stetsko; the final notice identified Mr. Stetsko as the “person             
          to contact” and provided his contact telephone number and                   
          employee identification number.  At that time, Mr. Stetsko was              
          classified as a GS-12 employee and a GS-1169 series revenue                 
          officer.  Petitioner received the final notice of intent to levy            
          on May 12, 2001.                                                            
               D.  Petitioner’s Request for a Hearing                                 
               On June 18, 2001, petitioner filed with respondent a Request           
          for a Collection Due Process Hearing in respect of his unpaid tax           
          liabilities for 1996 and 1997.  Petitioner’s Request for a Due              


               3  In authorizing the issuance of the notice required by               
          section 6320 and the filing of the Notice of Federal Tax Lien,              
          Ms. McCullough acted at the request of Group Manager Robert                 
          Winship.  As a group manager, Mr. Winship was the supervisor of             
          John Stetsko, a revenue officer who was assigned petitioner’s               
          account for collection.  See infra C.                                       





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