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of the date of the filing of the NFTL. Petitioner has not made
any payments toward his liability for 1998.
3. Petitioner’s 2000 Tax Return
Petitioner timely filed a Form 4868 for 2000. Petitioner
filed his Form 1040 for 2000 on April 30, 2001, reflecting a
total tax of $9,183. Respondent assessed the tax shown on the
return as well as an addition to tax for failure to pay tax of
$91.83. Respondent also credited to petitioner’s account $300
for the Immediate Tax Relief Credit on August 27, 2001.
Including interest, petitioner’s outstanding tax liability for
2000 was $9,061.78 as of the date of the filing of the NFTL.
Petitioner has not made any other payments toward his liability
for 2000.
On September 12, 2002, respondent filed an NFTL regarding
petitioner with respect to 1997, 1998, and 2000, in the Office of
the County Recorder for the County of Los Angeles, California.
On September 17, 2002, respondent sent petitioner a Letter 3172,
Notice of Federal Tax Lien Filing, by certified mail. In
response to the Letter 3172, petitioner timely filed with
respondent a Form 12153, Request for a Collection Due Process
Hearing (CDP hearing).
B. Petitioner’s Offer in Compromise
Petitioner submitted a Form 656, Offer in Compromise (OIC),
and a Form 433-A, Collection Information Statement For Wage
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Last modified: May 25, 2011