- 3 -
On or about March 18, 2003, respondent sent to
petitioner a Notice of Federal Tax Lien Filing and Your
Right to a Hearing Under IRC 6320 which stated that a
notice of Federal tax lien had been filed with respect to
taxable years 2000 and 2001 in the amounts of $143,165.96
and $45,675.28, respectively.
On the following day, March 19, 2003, respondent sent
to petitioner a final notice, Notice of Intent to Levy and
Notice of Your Right to a Hearing, with respect to the
amount petitioner owed for taxable year 2000. On the same
date, respondent sent a similar notice with respect to the
amount petitioner owed for taxable year 2001.
In response, petitioner timely filed a request for a
collection due process hearing. Petitioner’s request for
a hearing indicates his disagreement with respondent’s
“Notice of Levy/Seizure”. The hearing request does not
indicate petitioner’s disagreement with the notice of
Federal tax lien. Petitioner’s hearing request sets out
the following reasons for his disagreement with the notice
of levy/seizure:
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