Robert Harold Hathaway - Page 4

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          1997 with his letter.  In his letter, Appeals Officer Kelly                 
          stated that the tax petitioner reported when he filed his tax               
          return is the tax owed and that the amended tax returns are not             
               A telephone hearing was held as scheduled.  During that                
          hearing petitioner advanced tax-protester arguments regarding his           
          tax obligation and respondent’s filing of the Federal tax lien.             
          Petitioner did not raise any relevant issues relating to the                
          existence or amount of his unpaid taxes.  Nor did petitioner make           
          any offers of collection alternatives.                                      
               On November 2, 2001, a Notice of Determination Concerning              
          Collection Action Under Section 6320 (Lien) of the Internal                 
          Revenue Code was sent to petitioner.  In that notice, respondent            
          determined that the filing of a Federal tax lien was an                     
          appropriate collection action.  Petitioner then filed a petition            
          with this Court under section 6330(d) disputing respondent’s                
          determination.  See sec. 6320(c).                                           
               Section 6321 imposes a lien in favor of the United States              
          upon all property and rights to property belonging to a person              
          liable for unpaid taxes after demand for payment.  Within 5                 
          business days after the day of filing the notice of lien, the               
          Secretary must notify in writing the person against whom the lien           
          is filed (the taxpayer) that a tax lien was filed and inform the            

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