- 2 - Respondent issued to petitioner a Notice of Determination Concerning Collection Action(s) Under Sections 6320 And/Or 6330 (notice of determination). This Court must decide whether respondent abused his discretion in determining that the filing of the Notice of Federal Tax Lien was appropriate. Some of the facts in this case have been stipulated and are so found. Petitioner resided in West Covina, California, at the time he filed his petition. On February 9, 1999, respondent issued to petitioner a notice of deficiency for taxable year 1996. The notice of deficiency was sent to petitioner via certified mail, but it was returned to sender unclaimed. On November 8, 2000, respondent sent to petitioner a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 (notice of lien). On December 12, 2000, respondent received petitioner’s Request for a Collection Due Process Hearing (Appeals Office hearing), in response to the notice of lien. On July 16, 2001, petitioner met with an Appeals officer for petitioner’s Appeals Office hearing. At the Appeals Office hearing, petitioner claimed that he did not receive the notice of deficiency. The Appeals officer granted petitioner an audit reconsideration to discuss his 1996 income tax liability. On July 26, 2001, an examiner mailed to petitioner a letterPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011