- 4 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011