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D. Notices of Federal Tax Liens
On May 11, 2001, respondent filed notices of Federal tax
lien with respect to each petitioner’s transferee liability,
showing an $89,079.25 unpaid balance of assessment with respect
to each petitioner. In separate letters dated May 16, 2001,
respondent notified each petitioner of this action and of the
right to a hearing under section 6320.
E. Petitioners’ Requests for Hearings
Each petitioner timely submitted a Form 12153, Request for a
Collection Due Process Hearing. Attached to these Forms 12153
were substantially identical memoranda, asserting that each
asserted tax lien was defective, erroneous, and improper because:
(1) The stipulated decision in the corporation’s deficiency case
was jurisdictionally defective because the underlying notice of
deficiency was invalid in that it determined a deficiency for the
corporation’s taxable year ending December 31, 1995, rather than
for the corporation’s final taxable period ending August 31,
1995; and (2) alternatively, each transferee’s liability should
be limited to $19,041, which petitioners seemed to suggest was
the maximum value of assets that any of them actually received
from the corporation.
F. The Appeals Office Hearings
On July 25, 2001, an Appeals officer held a telephone
hearing with respect to the collection proceedings against
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Last modified: May 25, 2011