Jeffrey M. Young - Page 3




                                        - 3 -                                         
          560 (2000).  Petitioner has not filed a response to respondent’s            
          motion as required by our order of October 2, 2002.                         
               Petitioner filed Federal income tax returns for 1994, 1997,            
          1998, and 1999.  Those returns reported taxes due; however,                 
          petitioner did not pay the entire amount of the taxes shown on              
          his returns.  Respondent assessed the taxes reported and also               
          assessed additions to tax and interest.                                     
               On April 4, 2001, respondent issued to petitioner a “Notice            
          of Federal Tax Lien Filing and Your Right to a Hearing Under IRC            
          6320”.2  The lien filing was made with respect to unpaid taxes              
          stated as follows:                                                          
                    Type of tax       Period          Amount                          
                    1040      12/31/1994          $698.69                             
                    1040      12/31/1997          189.34                              
                    1040      12/31/1998          3,450.59                            
                    1040      12/31/1999          1,466.73                            
          Petitioner filed a Form 12153, Request for a Collection Due                 
          Process Hearing, with respect to the lien filing.  An attachment            
          to that Form 12153 states in pertinent part:                                
                    Summarizing, I am requesting a “Due Process                       
               Hearing” as outlined Form 12153. [sic] I am                            
               “challenging the appropriateness of (the) collection                   
               action” as specified in 6330(c)(2)(A)(ii) since the IRS                
               denied all of my requests of the initial “examinations”                
               and “interviews” as provided in Publications 1 & 5.  In                
               addition, no lien for taxes pursuant to Code Sections                  
               6321 and 6322 is possible because no valid, underlying                 


               2Respondent filed a Form 668(Y)(c), Notice of Federal Tax              
          Lien, with the prothonotary of Lackawanna County, Scranton,                 
          Pennsylvania.                                                               





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011