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section 6303(a).1
On April 8, 2004, respondent issued to petitioner a final
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to her taxable year 2000.
On April 19, 2004, in response to the notice of intent to levy,
petitioner filed Form 12153, Request for a Collection Due Process
Hearing (Form 12153), and requested a hearing with respondent’s
Appeals Office (Appeals Office). Petitioner indicated in her
Form 12153 that she did not agree with the “Filed Notice of
Federal Tax Lien”. However, respondent did not issue to peti-
tioner a notice of Federal tax lien filing with respect to her
taxable year 2000.
On October 13, 2004, respondent’s Appeals officer (Appeals
officer) held a telephonic conference (telephonic conference)
with petitioner. During that telephonic conference, petitioner
attempted to challenge the underlying tax liability for her
taxable year 2000. The Appeals officer refused to consider any
such challenge. That was because petitioner did not file a
petition with the Court with respect to the notice of deficiency
that she received from respondent with respect to her taxable
year 2000. Except for her attempted challenge of the underlying
tax liability for her taxable year 2000, petitioner raised no
1All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: May 25, 2011