Richard Mark Hansen - Page 8

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               Mr. Lin recommended that petitioner’s OIC be rejected                  
          because petitioner had the ability to satisfy his tax liabilities           
          in full and because petitioner was not current in making his                
          estimated tax payments.  By letter, petitioner was advised that             
          his proposed OIC was not acceptable.                                        
          D.   The Petition                                                           
               The petition filed with the Court covered tax years 1997,              
          1998, 1999, 2000, 2001, and 2002.  Because the notice of                    
          determination addressed only 1997, 1998, and 2000, respondent’s             
          motion to dismiss for lack of jurisdiction and to strike as to              
          the remaining years was granted.                                            
               In his petition, petitioner states:                                    
               Release of lien, abatement of penalties and interest, and              
               discharge of $50,000.00 for 1997 taxes.  There was no need             
               for the lien.  I was not properly notified and I was working           
               with the IRS at the time to resolve these issues.  Doubt as            
               to liability.  Doubt as to collectibility.  Econemic [sic]             
               hardship and unfair and inequitable.  I believe I do not owe           
               $50,000.00 for 1997 taxes.  This is based on Bad Advice,               
               Ignorance, and Mistakes Made by my tax attorney.  I believe            
               I qualify for the Offer in Compromise and or penalty and               
               interest abatement.                                                    
                                     Discussion                                       
          A.   Petitioner’s Underlying Liabilities                                    
               Section 6320 entitles a taxpayer to notice of the taxpayer’s           
          right to request a hearing after a notice of lien is filed by the           
          Commissioner in furtherance of the collection from the taxpayer             
          of unpaid Federal taxes.  The taxpayer requesting the hearing may           
          raise any relevant issue with regard to the Commissioner’s                  





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