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D. Hearing Request Relating to the Lien
On February 22, 2002, petitioner filed a Form 12153, Request
for a Collection Due Process Hearing, with respect to the notice
of Federal tax lien for tax year 1998. In the request,
petitioner contended that the notice of Federal tax lien was
invalid because the Secretary had not delegated authority to the
person who issued the notice. Petitioner attached to his request
for a hearing documents containing numerous frivolous arguments.
E. The Levy
Respondent levied upon petitioner’s wages from February 19
to April 4, 2002, to collect an amount equal to what respondent
had determined was petitioner’s 1998 tax liability. Petitioner’s
employer made the following payments: $993.33 on February 19,
2002; $1,712.16 on March 8, 2002; $1,013.10 on March 21, 2002;
and $8,095.54 on April 4, 2002. Respondent now concedes that
petitioner is entitled to a refund with respect to tax year 1998.
F. Hearing Relating to the Lien
On a date not specified in the record, respondent’s Appeals
officer conducted a hearing relating to petitioner’s lien for tax
year 1998. Petitioner asked to make an audio recording of the
hearing. Respondent denied that request. Petitioner attended
the hearing but did not record it. On May 23, 2002, respondent
issued to petitioner a Notice of Determination Concerning
Collection Action(s) in which respondent determined that the
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