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petition at docket No. 17597-02 challenging respondent’s final
notice under section 6015.
In the interim, on November 6, 2002, respondent issued to
petitioner a Final Notice of Intent to Levy and Notice of Your
Right to a Hearing for the taxable years 1989 to 1994. On
November 15, 2002, petitioner submitted to respondent a Request
for a Collection Due Process Hearing under section 6330.
On November 15, 2002, respondent issued to petitioner a
Notice of Federal Tax Lien Filing and Notice of Your Right to a
Hearing for the taxable years 1989 to 1994. On December 12,
2002, petitioner submitted to respondent a Request for a
Collection Due Process Hearing under section 6320.
On April 17, 2003, respondent issued to petitioner a Notice
of Determination Concerning Collection Action(s) for the years
1989 to 1994. Respondent conceded in the notice of determination
that it was improper to propose to levy on petitioner’s property
prior to the entry of a final determination regarding her claims
for relief under section 6015. On the other hand, respondent
determined that it was not improper to file a Federal tax lien
against petitioner prior to the entry of a final determination
regarding her claims for relief under section 6015.
On May 19, 2003, petitioner filed with the Court a petition
for lien or levy action challenging respondent’s notice of
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Last modified: May 25, 2011