Michael Stein - Page 11

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               Lien Proceeding                                                        
               On January 31, 2000, Revenue Officer Donald Angotta (Revenue           
          Officer Angotta) replaced Revenue Officer Mele for purposes of              
          collecting petitioner’s 1992 through 1994 tax liabilities.                  
               On February 23, 2000, respondent filed an NFTL with respect            
          to petitioner’s 1992 through 1994 tax liabilities against                   
          petitioner’s real property at the land record office in Stamford,           
          Connecticut.  The lien attached to the condominium unit                     
          petitioner owned at the Strawberry Hill address.                            
               On February 23, 2000, respondent’s lien unit office mailed             
          petitioner Letter 3172, Notice of Federal Tax Lien Filing and               
          Your Right to a Hearing Under IRC 6320, to the Strawberry Hill              
          address, with a copy of the NFTL and a Form 12153.                          
               On March 15, 2000, respondent received from petitioner a               
          Form 12153 with an attached letter to Revenue Officer Angotta and           
          an attached memorandum (the attached memorandum).  On the Form              
          12153, petitioner listed his telephone number and instructed the            
          IRS to write to petitioner’s post office box address, which he              
          said he checked twice a month, if the IRS was unable to reach him           
          by telephone.  Petitioner placed the words “See Attachment”,                
          apparently referring to the attached memorandum, under both                 
          notations on the Form 12153 that allowed him to appeal either a             
          “Filed Notice of Federal Tax Lien” or a “Notice of Levy”.                   








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