Howard Dysle - Page 3

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               On December 31, 2001, respondent abated $2,149 in tax for              
          1996.  Respondent subsequently abated portions of the additions             
          to tax and interest for 1996 to reflect the revised assessment of           
          tax of $4,471 (i.e., $6,620 minus $2,149) for 1996.                         
               On or about June 6, 2002, respondent filed a notice of                 
          Federal tax lien regarding petitioner’s 1996 and 1998 tax years             
          (notice of lien).  As of the date of the notice of lien,                    
          petitioner’s unpaid balance was $6,584.99 for 1996 and $96.75 for           
          1998.                                                                       
               On June 11, 2002, respondent sent petitioner a Notice of               
          Federal Tax Lien Filing and Your Right to a Hearing Under IRC               
          6320 regarding petitioner’s 1996 and 1998 tax years (hearing                
          notice).                                                                    
               On June 20, 2002, petitioner timely filed a Form 12153,                
          Request for a Collection Due Process Hearing, regarding his 1996            
          and 1998 tax years (hearing request).  In the hearing request,              
          petitioner stated that he had not been credited with payments he            
          made to the Internal Revenue Service (IRS).  In a supplemental              
          Form 12153 submitted to the IRS regarding his 1993 through 2000             
          tax years, petitioner stated that he did not owe the IRS anything           
          and that the IRS failed to credit petitioner with payments he               
          made.                                                                       









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