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During the period surrounding his marital separation and the
onset of his illness, petitioner found it difficult to cope with
his financial affairs. He did not file Federal income tax
returns for 1997 or 1998. Petitioner then filed his 1999 return,
which was posted at the Internal Revenue Service Center on May
29, 2000. The return reported a tax liability that was not fully
paid either by withholdings or by any payment submitted with the
return. Respondent made no adjustments to petitioner’s 1999
reporting and accepted the return as filed.
Following assessments of petitioner’s tax liabilities for
1995, 1996, and 1999, respondent on or about September 5, 2000,
filed a notice of Federal tax lien with the Judge of Probate in
Mobile County, Alabama. The notice of lien reflected a total
unpaid balance of $7,235.61, comprising $1,726.20 for 1995,
$4,361.32 for 1996, and $1,148.09 for 1999. Then, on September
8, 2000, respondent issued to petitioner a Notice of Federal Tax
Lien Filing and Your Right to a Hearing Under IRC 6320 regarding
the just-described lien.
Respondent on October 10, 2000, received from petitioner a
Form 12153, Request for a Collection Due Process Hearing, with
the following explanation of his disagreement with the lien:
“12-31-95 and 12-31-96 is [sic] not correct. Would like to
explain at the hearing or over the phone”. Appeals Officer
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