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filed with the County Recorder, Maricopa County, Arizona, a
Notice of Federal Tax Lien regarding petitioner’s unpaid income
taxes for 1993 to 1997. On March 13, 2003, respondent issued to
petitioner a Notice of Federal Tax Lien Filing and Notice of Your
Right to Hearing for the years 1993 to 1997. On April 4, 2003,
petitioner submitted to respondent a Form 12153, Request for
Collection Due Process Hearing, challenging the validity of the
assessments for the years in issue.
On August 20, 2003, petitioner appeared at respondent’s
Appeals Office for an administrative hearing under sections 6320
and 6330. However, the hearing was aborted when the Appeals
officer informed petitioner that he would not be permitted to
make an audio recording of the hearing.
On September 9, 2003, the Appeals Office issued to
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 sustaining the filing of
the tax lien and determining that it was appropriate to proceed
with the proposed levy. The Appeals Office concluded that
petitioner had previously challenged respondent's notices of
deficiency for 1993 to 1997 in the Tax Court, and, therefore, he
was barred from challenging the existence or amount of those tax
liabilities pursuant to section 6330(c)(2)(B). The Appeals
officer verified that all administrative and legal procedures
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Last modified: May 25, 2011