- 24 - Notice of the lien filing may be given to the taxpayer in person, left at the taxpayer’s dwelling, or sent by certified or registered mail to the taxpayer’s last known address. Sec. 6320(a)(2). On February 23, 2000, respondent timely mailed to petitioner’s Strawberry Hill address, Letter 3172, with a copy of the NFTL. Petitioner sent a Form 12153 that was received by respondent on March 15, 2000, within 30 days of respondent’s filing of the NFTL and the mailing of the Letter 3172. Petitioner sent the Form 12153 to appeal the February 14, 2000, “levy warning letter” he claims was issued by Revenue Officer Angotta. On December 8, 2000, respondent provided petitioner with a section 6320 hearing to contest the filing of the NFTL. Because the hearing had been timely requested within the prescribed 30- day period, petitioner’s claims that respondent did not send Letter 3172 to petitioner’s last known address and that petitioner never received it are beside the point. Even though, in the Form 12153, petitioner appealed an alleged “levy warning letter”, Appeals Officer Hirsch’s letters sent to petitioner before the section 6320 hearing clearly indicated that the section 6320 hearing would deal with the NFTL.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011