- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011