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In 2001, respondent assessed the tax, penalty, and interest for
1995. During 2001, petitioner’s tax deficiency for 1995 of
$440,042 was paid out of the seized funds.
On June 28, 2001, respondent filed a notice of Federal tax
lien regarding petitioner’s 1995 tax year (notice of lien). That
same day, respondent sent petitioner a copy of the notice of
lien.
On July 25, 2001, petitioner timely filed a Form 12153,
Request for a Collection Due Process Hearing, regarding his 1995
tax year. In the hearing request, petitioner stated: “I believe
these taxes were paid from the monies seized by U.S. Customs.”
On November 8, 2001, respondent mailed petitioner a letter
identifying Appeals Officer Fernando Orozco as assigned to
consider the collection action and to conduct petitioner’s
hearing.
Petitioner had a correspondence hearing with Appeals. On
November 25, 2001, petitioner wrote Appeals Officer Orozco a
letter setting forth petitioner’s position regarding his case.
Petitioner claimed that his total tax liability for 1995,
including penalties and interest, had been paid.
On November 29, 2001, Appeals Officer Orozco prepared an
Appeals transmittal and case memorandum. Appeals Officer Orozco
noted that petitioner was convicted of tax evasion, and that the
Internal Revenue Service (IRS) had received a payment of
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Last modified: May 25, 2011