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deficiency of $3,137 for the year. Petitioner attempted to
challenge respondent’s determination, but her petition was not
timely filed, and her case was dismissed by this Court.
For taxable year 1998, petitioner’s tax liability resulted
from a computational error she made on her return. For 2000 and
2001, petitioner failed to pay the taxes she had properly
reported on her returns. Respondent did not issue to petitioner
statutory notices of deficiency for 1998, 2000, or 2001.
Respondent filed a Notice of Federal Tax Lien (NFTL) with
respect to petitioner’s tax liabilities for 1996, 1997, 1998,
2000, and 2001. Petitioner filed requests for an administrative
hearing with respect to the filing of a Federal tax lien under
section 6320.
In addition, respondent issued to petitioner a Final Notice-
-Notice of Intent to Levy and Notice of Your Right to a Hearing
with respect to her 2000 and 2001 tax liabilities. On September
19, 2002, pursuant to section 6330 petitioner filed a request for
a hearing with respect to respondent’s proposed levy actions for
2000 and 2001.
On May 21, 2003, petitioner met with an officer from
respondent’s Appeals Office to discuss the filing of the Federal
tax lien and the proposed levy actions.
With respect to the NFTL, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
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