Johnny Owings Milam, Jr. and Brenda Ramsey Milam - Page 10

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               E.  Notice of Federal Tax Lien                                         
               Petitioners next contend that the Notice of Federal Tax Lien           
          Filing and Your Right to a Hearing Under IRC 6320 and the Notice            
          of Federal Tax Lien (filed with the Clerk of Superior Court in              
          Pender County, North Carolina) were invalid because they were not           
          signed under penalties of perjury as required by section 6065.              
          As previously discussed, documents prepared by respondent need              
          not comply with section 6065.  Petitioners admit receiving the              
          Notice of Federal Tax Lien Filing.  Consequently, petitioners               
          have identified no defect with respect to this notice of the                
          lien’s filing.                                                              
               F.  Examination Interview and Administrative Appeal                    
               Petitioners also allege error in that they were not given              
          the opportunity for an “examination interview” or for an                    
          administrative appeal prior to the issuance of the notice of                
          deficiency.  However, it is well established that taxpayers have            
          no entitlement to any such interview or appeal prior to the                 
          issuance of a notice of deficiency.  See, e.g., Luhring v.                  
          Glotzbach, 304 F.2d 560, 563 (4th Cir. 1962); Edwards v.                    
          Commissioner, T.C. Memo. 2002-169 (and cases therein cited).                
          Accordingly, the failure by respondent to grant petitioners an              
          examination interview or administrative appeal prior to issuance            
          of the notice of deficiency in no way invalidates the notice with           








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