- 3 - Respondent issued to petitioner by certified mail a statutory notice of deficiency for 1998 on February 11, 2000, and for 1999 on March 30, 2001. Petitioner did not file a petition with this Court in response to either notice of deficiency, and respondent assessed the taxes, additions to tax, penalty, and/or interest for 1998 on August 14, 2000, and for 1999 on September 24, 2001. A notice of balance due was promptly sent to petitioner with respect to each year. Thereafter, respondent issued to petitioner a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 regarding his unpaid liabilities for 1998 and 1999. On or about April 16, 2003, petitioner submitted to respondent a Form 12153, Request for a Collection Due Process Hearing, setting forth his disagreement with the lien. He challenged, among other things, the validity of the assessments, the issuance of a statutory notice of deficiency or notice and demand for payment, and the authority of Internal Revenue Service personnel. A cover letter with the Form 12153 indicated that petitioner had initially attempted to respond to respondent’s proposed collection activities by a letter dated March 26, 2003, and also stated petitioner’s intention to record the requested hearing. The Appeals officer to whom petitioner’s case had been assigned subsequently scheduled a hearing for July 2, 2003, in Las Vegas, Nevada. Petitioner appeared for the scheduled hearingPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011