- 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