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that he had scheduled a telephonic Appeals Office hearing with
petitioner on June 9, 2004, at 10 a.m., with respect to the
notice of tax lien (scheduled Appeals Office hearing). On June
8, 2004, the day before the scheduled Appeals Office hearing,
petitioner and petitioner’s authorized representative telephoned
the Appeals officer (June 8, 2004 telephone call).
On July 19, 2004, the Appeals Office issued to petitioner a
notice of determination concerning collection action(s) under
section 6230 and/or 6330 (notice of determination). The notice
stated in pertinent part:
Based on the available facts Compliance followed the
applicable procedures and the issuance of the Notice of
Federal Tax Lien was proper and appropriate.
An attachment to the notice of determination stated in
pertinent part:
Summary and Recommendation
Collection Due Process--Lien
You submitted a timely Request for a Collection Due Process
Hearing under Internal Revenue Code Section 6320 in
response to a Notice of Federal Tax Lien Filing against
a 1040 (Individual Income tax) liability for the year
ending 12/31/96.
Letter 3172, (Notice of Federal Tax Lien Filing) was
issued by the Compliance Division of the Cherry Hill,
New Jersey Field Office on November 6, 2003. Form
12153, (Request for a Collection Due Process Hearing)
was received by Compliance on December 9, 2003.
Summary of Issues
You have raised no specific issues other than frivolous
and groundless arguments.
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Last modified: May 25, 2011