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On January 29, 2001, petitioners, through their attorney
Deborah Jaffe,3 filed a Form 12153, Request for a Collection Due
Process Hearing. In their “Statement in Support of Form 12153”
petitioners identified three issues to be discussed at the
hearing. First, petitioners disputed the amount of the tax
liability set forth in the notice of Federal tax lien. The
statement in support of Form 12153 stated:
The taxpayers are in the process of determining the
correct amount of their income tax liabilities for
these years, and they anticipate that their actual
liability will be substantially less than as set forth
in the notice of Federal tax lien. While the taxpayers
acknowledge that the liability set forth in the notice
was assessed based on a 1997 return filed by the
taxpayers, that return as filed was incorrect, and the
taxpayers had so advised the Internal Revenue Service
prior to the filing of the notice of Federal tax lien.
Second, petitioners claimed that the “notice of Federal tax lien
was filed despite the taxpayers’ cooperation with the IRS”.
Third, petitioners claimed that the filing of the notice of
Federal tax lien would hinder the ability of the IRS to collect
the tax liabilities because potential investors would not invest
in BP Concessions if a Federal tax lien was filed.
On March 20, 2001, Appeals Settlement Officer J.A. Vander
Linden wrote to Ms. Jaffe regarding the Appeals process. On May
14, 2001, Ms. Jaffe proposed a settlement to Appeals Settlement
Officer Vander Linden. The settlement proposed filing of
3 On Sept. 18, 2002, the Court granted Ms. Jaffe’s motion
to withdraw as counsel of record.
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Last modified: May 25, 2011