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Brief Background
Your liability is the result of an audit deficiency.
As a result of an audit it was determined that an
additional tax was due to omitted income related to
what was determined to be an abusive trust.
Your account was subsequently assigned to Compliance
for collection of the unpaid tax. Attempts were made
by Compliance to resolve your liability. As one of its
subsequent case actions Compliance filed a Notice of
Federal Tax Lien. You responded by submitting a
Request for a Collection Due Process hearing.
Compliance forwarded your case file along with all
supporting documentation to the Newark, New Jersey
Office of Appeals for consideration where your hearing
request was assigned to a Settlement Officer who had no
previous involvement with your account.
Requirement of Law and Administrative Procedures
Law
IRC Section 6321 provides for a statutory lien when a
taxpayer neglects or refuses to pay a tax liability
after notice and demand. A review of your account
transcript indicates that Notice and Demand for payment
was made on the amount due for the year ending 12/31/96
and the obligation remained unpaid.
IRC Section 6320(a) provides that the Internal Revenue
Service will notify a taxpayer of the filing of a
Notice of Lien and of the Right to a Hearing before the
Internal Revenue Service Office of Appeals with respect
to the filing of a Notice of Federal Tax Lien. Such
notification was given to you by Compliance by the
issuance of Letter 3172 by certified mail, return
receipt requested, on November 6, 2003.
In accordance with IRC Section 6330(c) you were given
the opportunity to raise any relevant issue relating to
the unpaid tax or the Notice of Federal Tax Lien at a
telephone held on June 8, 2003.
A review of your account transcript indicates that the
assessment was made on the applicable collection due
process notice period in accordance with IRC Section
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Last modified: May 25, 2011