- 7 -
E. Respondent’s Notice of Determination
On February 12, 2003, respondent issued to petitioner a
Notice of Determination Concerning Collection Action(s) in which
respondent determined that the filing of the tax lien for 1992-94
was appropriate.
Petitioner timely filed a petition. In the petition,
petitioner disputed the underlying tax liabilities for 1992 and
1994 on the grounds that respondent had not applied a credit from
a later year to those years and contended that respondent
recorded the tax lien despite the fact that the Taxpayer Advocate
had placed a 45-day hold on collection 12 days earlier.3
OPINION
1. Respondent’s Contentions
Respondent contends that (a) respondent was not required to
provide petitioner an opportunity for a hearing at the Appeals
Office closest to petitioner’s residence, and (b) petitioner
waived any right to a hearing because petitioner had a telephone
conference with Magee in lieu of attending the conference at
Jackson, Mississippi.
3 Congress contemplated the withdrawal of a Federal tax lien
in appropriate circumstances, such as after the involvement of
the Taxpayer Advocate. See sec. 6323(j)(1)(D).
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011