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On or about May 15, 2001, respondent prepared a notice of
Federal tax lien to assist in the collection of the cumulative
unpaid balance then accrued on petitioner’s 1995 through 1997 tax
liabilities. On May 21, 2001, respondent sent petitioner an IRS
“Letter LT-11 - FINAL NOTICE: NOTICE OF INTENT TO LEVY AND
NOTICE OF YOUR RIGHT TO A HEARING”. On May 24, 2001, respondent
sent petitioner an IRS “Letter 3172(DO) - NOTICE OF FEDERAL TAX
LIEN FILING AND YOUR RIGHT TO A HEARING UNDER IRC 6320”. On May
30, 2001, the notice of Federal tax lien prepared by respondent
on May 15, 2001, was filed with the Chancery Court Clerk, Hinds
County - District 1, Jackson, Mississippi.2
On June 18, 2001, petitioner mailed respondent IRS “Form
12153 - Request for a Collection Due Process Hearing” in response
to both the May 21, 2001, IRS “Letter LT-11” and the May 24,
2001, IRS “Letter 3172(DO)” referred to above. The Form 12153
was received by respondent on June 26, 2001. In the Form 12153
petitioner alleged that respondent, without petitioner’s prior
consent, acted improperly in transferring overpayment credits in
her 1995 through 1997 tax accounts to the Department of Human
2Respondent's lien notice in the amount of $12,830.88
appears to be incorrect in two respects: It contains a
typographical error in the statement of the 1996 deficiency and
accrued interest, which causes the lien amount set forth in the
notice to be $400 less than the total assessed liabilities
summarized in the table above, and it fails to give petitioner
credit for the application of her refund for the tax year 2000
against the balance due on her 1995 tax year account.
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Last modified: May 25, 2011