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testimony on this matter on cross-examination included the
following:
Q Mr. Call, you say that you never received a
copy of the notice of the Federal Tax lien filed?[4]
A No, sir. I got one when I found the notice
from Credit Watch in my e-mail actually. I went to the
County Recorder and got a copy of the notice of tax
lien that was filed, or actually there was two of them.
There was one for each year, but I got my
copies of the notices of a tax lien from the County
Recorder’s order.
Q And you still managed to get that in time to
file a request for a CDP hearing?
A Yes, sir, apparently I did.
Q Do you have a date of notice from this Credit
Watch Service or any sort of a document that indicates
when you received it originally?
A I have the notices that I picked up from the
County Recorder, and I think they have a stamp on them.
I am not absolutely certain, but I think they stamped
it or date stamped it.
He later added:
I am assuming that the Credit Watch notified me, I
guess, within a day or two of the time that the notice
of tax lien was filed at the County Recorder.
And I was probably at the Recorder’s office the
next day possibly, and possibly the same day. I don’t
remember. But I didn’t dillydally. I went up there
and got that, knowing that my time was limited to file.
4 The Court notes that sec. 6320(a)(1) by its terms requires
only that a taxpayer be given notification that a tax lien has
been filed, not that a copy of the notice of tax lien so filed be
furnished to the taxpayer.
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