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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.
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