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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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Last modified: May 25, 2011