- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011