Kevin P. Burke - Page 5

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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