- 3 - with regard to his 1986, 1990, and 1991 tax liabilities. This notice was returned marked “No Longer At This Address/Addressee Unknown”. On September 22, 1993, respondent sent petitioner a Final Notice (Notice of Intent to Levy) by certified mail to the Ohio address. On September 27, 1993, petitioner signed for the notice. In October of 1993, petitioner’s address in respondent’s master file was changed to the Ohio address after a collection officer verified that the address was valid. C. First Levy and Sale On July 24, 1995, respondent levied upon petitioner’s home and vehicle (the property). On October 6, 1995, respondent sold the property by sealed bid to Alum Cliff Industries (ACI). Petitioner was never personally served with notice of the sale. Respondent applied $10,583.24 of the sale proceeds to petitioner’s unpaid 1990 tax liability. D. Reversal of Sale and of Credit to Petitioner’s Tax Account In 1995, petitioner brought suit in the U.S. District Court for the Southern District of Ohio against various defendants, including the Internal Revenue Service (IRS) and ACI. See McIntosh v. United States, 82 AFTR 2d 98-6501 (S.D. Ohio 1998). In this suit petitioner sought, among other things, to quiet title to the property. Admitting procedural irregularities in failing to provide petitioner with notice of the sale of thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011