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On December 7, 2001, the IRS filed a notice of Federal tax
lien for income taxes (including additions to tax and interest)
owed by petitioner for 1996-99. On December 11, 2001, the IRS
sent petitioner a Form 3172, Notice of Federal Tax Lien Filing
and Your Right to a Hearing Under IRC 6320, and a Form 12153,
Request for a Collection Due Process Hearing. On January 7,
2002, petitioner submitted a completed Form 12153 to the IRS.
Petitioner’s case was assigned to Appeals Officer James H.
Reagan. On April 2, 2002, Appeals Officer Reagan sent petitioner
a letter in which a face-to-face hearing, as authorized by
section 6320, was scheduled. Per that letter, the topics to be
discussed at the hearing included the additions to tax at issue,
as well as the reinstatement of the installment agreement. The
hearing was held as scheduled.
On June 20, 2002, Appeals Officer Reagan sent petitioner a
letter in which Appeals Officer Reagan recommended that
petitioner consider making a partial payment and pay the balance
due the IRS in installments. The letter stated that if
petitioner wanted to enter into an installment agreement, then,
by July 8, 2002, petitioner would have to complete a Form 433-A,
Collection Information Statement for Wage Earners and Self-
Employed Individuals, (which was enclosed with Appeals Officer
Reagan’s letter) and provide Appeals Officer Reagan with copies
of petitioner’s personal and business bank statements and check
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Last modified: May 25, 2011