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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 letter
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