- 3 -
and 1996. Pursuant to that consent, respondent assessed the
following amounts on March 8, 2004:
1995 1996
additional tax $55,639.00 $8,373.00
fraud penalty 41,729.25 6,279.75
interest 78,418.20 9,578.91
On that same date, respondent sent petitioner a notice of
balance due (i.e., a notice and demand for payment).
In the interim, on February 24, 2004, petitioner submitted
to respondent an offer-in-compromise on the basis of doubt as to
collectibility with regard to her tax liabilities for 1995 and
1996. Petitioner offered to pay $10,000 to respondent within 90
days of her offer. Respondent rejected petitioner’s offer-in-
compromise after concluding that she had sufficient equity in her
residence to pay the taxes in dispute.
At some point during the summer of 2004, petitioner executed
a new Form 2848 appointing Alvin Brown (Mr. Brown) to serve as
her representative with regard to her income tax liabilities for
1995 and 1996.
On August 17, 2004, respondent filed a Notice of Federal Tax
Lien at the County Courthouse in Broward County, Florida, with
regard to petitioner’s unpaid liabilities for 1995 and 1996. On
August 24, 2004, respondent mailed to petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 for 1995 and 1996 (the lien notice). In response to the
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011