- 4 - respondent filed a notice of Federal tax lien in Dade County, Florida, with respect to petitioner’s 1995-96 income taxes. On January 11, 2002, petitioner submitted to respondent six Forms 1040EZ, Income Tax Return for Single and Joint Filers With No Dependents, for 1995-2000. Petitioner entered zeros for his income and on the lines for total tax. Respondent assessed frivolous return penalties under section 6702 for those returns. Petitioner filed claims for refund for 1995 and 1996 early in 2002. Respondent rejected those claims on March 13, 2003. Petitioner filed his 2002 return on October 8, 2003. On January 16, 2004, respondent filed a notice of Federal tax lien in Alachua County, Florida, with respect to petitioner’s income tax liabilities for 1995-96 and frivolous return penalties under section 6702 for 1995-2000. On January 20, 2004, respondent sent petitioner a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC � 6320 relating to petitioner’s income tax liabilities for 1995-96 and frivolous return penalties for 1995-2000 (the January 2004 lien notice). On February 18, 2004, petitioner submitted to respondent an unsigned Form 12153, Request for a Collection Due Process Hearing. Respondent returned it to petitioner and asked that he sign and return it to respondent. Petitioner did so. On May 13, 2004, respondent’s Office of Appeals sent petitioner a letter: (1) Explaining the hearing process underPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011