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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 hearing
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