Phillip and Gladies Aaron - Page 6

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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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