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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.
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