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“Request without predjudice [sic] that hearing be held after
Superior Court Action FN 2003-092649 is adjudicated.”
Mr. Tracy responded by a letter to petitioner dated November
13, 2003, stating:
I am in receipt of Form 12153 signed by you and Scott
Picchiottino on November 7, 2003. It states only that
you wish a hearing after Superior Court Action FN 2003-
092649. I understand that this is your divorce suit.
I am sorry, but I cannot defer action on your case for
an extended and indefinite period of time. I am
extending to you the hearing opportunity that you had
originally requested on March 10, 2003.
I have enclosed a copy of my letter dated November 5,
2003. The hearing was scheduled with Scott
Picchiottino. I have left several messages for you to
schedule an independent hearing but you have not
responded to my messages. Please call me at (602)207-
8117 to schedule the hearing that you requested. If we
cannot schedule and hold your hearing by December 10,
2003, I will make my determination based on information
in the file and with no further opportunity for a
hearing. You are welcome to attend the November 25
hearing or to schedule an independent hearing with me.
If you no longer want a hearing, please sign and return
the enclosed withdrawal form.
You are entitled to a hearing under Sections 6320 and
6330 of the Internal Revenue Code (IRC) relative to the
2001 tax year. Your hearing request lists additional
years of liability that are not assessed in your name.
Those tax periods do appear to be community debts and
for which community property is subject to the Federal
Tax Lien.
Your original hearing request said only, “Told status
was ‘uncollectible’ by IRS Mrs. Hernandez #893695".
Indeed, Compliance did place your account in
temporarily not collectible status shortly after the
date of your hearing request.
The IRC 6320 hearing opportunity is relative to the
Notice of Federal Tax Lien that was recorded for the
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