- 5 - “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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011