- 3 -
On March 10, 2003, respondent sent petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 regarding petitioner’s 1994, 1995, and 1996 tax years.
On March 14, 2003, petitioner sent respondent a Form 12153,
Request for a Collection Due Process Hearing, regarding his 1994,
1995, and 1996 tax years.2 In a 22-page attachment to the Form
12153, petitioner essentially challenged his underlying tax
liability.
On July 10, 2003, petitioner mailed respondent three Forms
1041, U.S. Income Tax Return for Estates and Trusts, and Forms
W-2, Wage and Tax Statement, for 1994, 1995, and 1996.
On September 3, 2003, a face-to-face hearing was held with
petitioner, Appeals Officer Nancy J. Driver, and Appeals
Collection Specialist Veronica Smith. Appeals Officer Driver
confirmed that respondent had complied with all applicable laws
and administrative procedures regarding 1994, 1995, and 1996, and
she reviewed the administrative file for those years. Petitioner
did not propose any collection alternatives at the hearing and
stated he was not interested in discussing collection
alternatives because he did not believe he owed the amounts in
2 On the face of the Form 12153, petitioner listed 1994 and
1995 as the taxable periods. In his 22-page attachment to the
Form 12153, petitioner referenced 1996. Additionally, on Apr. 9,
2003, petitioner filed a second Form 12153 on which he listed
1996 as the taxable period. Respondent does not dispute that
petitioner timely requested hearings to challenge all 3 years.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011