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9, 2000, respondent assessed an income tax deficiency of
$905,315, an estimated tax penalty of $48,186, a miscellaneous
penalty of $656,353, a failure to pay penalty of $9,053, and
interest of $234,073.
Notice of Federal Tax Lien
On or about April 18, 2002, respondent filed the notice of
Federal tax lien with the County Comptroller of Orange County,
Florida, showing “Unpaid Balance of Assessment” for 1996 in the
amount of $1,852,980. On April 24, 2002, respondent issued to
petitioner Letter 3172, Notice of Federal Tax Lien Filing and
Your Right to a Hearing Under I.R.C. 6320.
Collection Due Process Hearing
On May 3, 2002, petitioner timely requested a hearing under
section 6320 (collection due process hearing). In that request,
petitioner opposed the filing of the NFTL and noted the $2
million remittance, which, he argued, had satisfied his 1996 tax
liability. Because petitioner was incarcerated, the Appeals
Office accorded petitioner the collection due process hearing by
way of an exchange of correspondence. During the course of the
hearing, a settlement officer conducting the hearing for the
Appeals Office learned of the forfeiture order and respondent’s
disposition of the $2 million remittance.
On January 10, 2003, the Appeals Office sent to petitioner a
Notice of Determination Concerning Collection Action(s) Under
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Last modified: May 25, 2011