Ella Louise Wooten - Page 5

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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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