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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 under
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Last modified: May 25, 2011