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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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Last modified: May 25, 2011