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Your Right to a Hearing Under IRC 6320 with respect to the 1996
and 1997 years.
Petitioners then submitted a Form 12153, Request for a
Collection Due Process Hearing, which was received by respondent
on April 27, 2001. On the Form 12153 petitioners checked boxes
indicating disagreement with both a “Filed Notice of Federal Tax
Lien” and a “Notice of Levy/Seizure”. They also attached a
statement explaining that their reasons for disagreeing included
that they were never given the Tax Court hearing they requested
on March 18, 2000, and that they primarily disputed the
disallowance in its entirety of $53,541 claimed in 1997 as cost
of good sold.
In response to that portion of petitioners’ request which
related to the notice of intent to levy, respondent held a so-
called equivalency hearing and, on January 24, 2002, issued a
Decision Letter Concerning Equivalent Hearing Under Section 6320
and/or 6330 concluding that the subject levy was an appropriate
collection action. In response to that portion of petitioners’
request which pertained to the notices of lien filing, respondent
held a “Collection Due Process” hearing and sent to petitioners a
Notice of Determination Concerning Collection Actions(s) Under
Section 6320 and/or 6330 dated February 28, 2002. An attachment
to the notice of determination explained in relevant part as
follows:
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Last modified: May 25, 2011