- 4 - lien notice, Mr. Brown submitted to respondent a timely request for an administrative hearing. On November 5, 2004, petitioner submitted to respondent Form 433-A, Collection Information Statement for Wage Earners and Self-Employed Individuals, and Form 433-B, Collection Information Statement for Business. On December 8, 2004, Settlement Officer Elsie Stewart of respondent’s Appeals Office in Plantation, Florida, held a telephonic conference with Mr. Brown and petitioner regarding petitioner’s case. Mr. Brown asserted that the assessments for 1995 and 1996 should be abated because they were: (1) Incorrect; (2) entered without issuance of a statutory notice of deficiency; and (3) entered after the expiration of the normal 3-year period of limitations. On February 18, 2005, respondent’s Appeals Office mailed to petitioner a Notice Of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, sustaining the filing of the notice of Federal tax lien against petitioner. On March 17, 2005, petitioner timely filed with the Court a petition challenging respondent’s notice of determination.2 Petitioner alleged in the petition that respondent erred in determining that she could not challenge the existence or amount 2 At the time that the petition was filed, petitioner resided in Ft. Lauderdale, Fla.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011