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Background
On or about April 12, 2001, respondent issued a “Final
Notice of Intent to Levy and Notice of Your Right to a Hearing”
to petitioner for his tax liabilities for 1989, 1993, 1994, and
1996. On or about May 2, 2001,2 respondent issued a “Notice of
Federal Tax Lien and Notice of Your Right to a Hearing” to
petitioner for his tax liabilities for 1989, 1993, 1994, and
1996.
Pursuant to the aforementioned notices, petitioner requested
a section 63303 hearing. On June 4, 2002, respondent issued a
notice of determination concerning collection action(s) under
section 6320 and/or 6330 sustaining the proposed collection
action. On July 3, 2002, petitioner filed a petition for lien or
levy action under Code section 6320(c) or 6330(d).
On or about August 7, 2002, in order to refinance his home,
petitioner paid in full his then-outstanding income taxes,
1(...continued)
however, petitioner eventually made it clear that the only remedy
he was seeking from the Court was for the IRS to reverse the levy
action and remove the lien that was filed--he was not requesting
a refund in this proceeding. Additionally, petitioner did not
dispute his underlying liabilities.
2 In the attachment to the notice of determination it
states that this notice was issued on Apr. 6, 2001. The date of
this notice is not in issue as respondent concedes that
petitioner timely filed his request for a sec. 6330 hearing.
3 Unless otherwise indicated, all section references are to
the Internal Revenue Code.
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Last modified: May 25, 2011