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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
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Last modified: May 25, 2011