- 4 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011