Dina DeSalvo - Page 4

                                        - 3 -                                         
          respondent assessed the unpaid liability, interest, and an                  
          addition to tax for failure to pay tax under section 6651(a)(2).            
               On or about August 18, 1997, petitioner entered into an                
          installment payment agreement which included the years 1993 and             
          1994.  The terms of the agreement required petitioner to comply             
          with future filing requirements, to pay all tax liabilities, and            
          to submit to future review to determine whether petitioner’s                
          financial circumstances warranted a change in payment terms.                
          Petitioner was subsequently asked to provide updated financial              
          information, but failed to do so.  Petitioner’s failure to pay              
          her 2000 tax liability, as well as her violation of the above               
          provisions requiring the submission of updated financial                    
          information upon request, caused petitioner to be in default of             
          her installment agreement.                                                  
               Respondent sent to petitioner’s last known address a Notice            
          of Federal Tax Lien Filing and Your Right to a Hearing Under                
          Section 6320 (lien notice), dated March 4, 2003, advising                   
          petitioner that a notice of Federal tax lien had been filed with            
          respect to her unpaid liabilities for taxable years 1993, 1994,             
          and 2000, and that petitioner could receive a hearing with                  
          respondent’s Office of Appeals.                                             
               On March 24, 2003, petitioner timely filed a Form 12153,               
          Request for a Collection Due Process Hearing for taxable years              








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011