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respect to the notice of deficiency relating to her taxable years
1997, 1998, and 1999.
On July 8, 2002, respondent assessed petitioner’s tax, as
well as additions to tax and interest as provided by law, for
each of her taxable years 1997, 1998, and 1999. (We shall refer
to those unpaid assessed amounts, as well as interest as provided
by law accrued after July 8, 2002, as petitioner’s unpaid liabil-
ities for 1997, 1998, and 1999.)
Respondent issued to petitioner the notice and demand for
payment as required by section 6303(a) with respect to peti-
tioner’s unpaid liabilities for 1997, 1998, and 1999.
On March 24, 2003, respondent issued to petitioner a notice
of Federal tax lien filing and your right to a hearing (notice of
tax lien) with respect to petitioner’s unpaid liabilities for
1997, 1998, and 1999.
On or about April 6, 2003, in response to the notice of tax
lien, petitioner filed Form 12153, Request for a Collection Due
Process Hearing (Form 12153), and requested a hearing with
respondent’s Appeals Office (Appeals Office). The following is
the only explanation that petitioner provided in her Form 12153
for her disagreement with respondent’s proposed collection
action: “Mathmaticly [sic] incorrect”.
On a date not disclosed by the record, a settlement officer
with the Appeals Office (settlement officer) held a telephonic
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Last modified: May 25, 2011