- 5 - petitioner transcripts of his tax accounts. These transcripts reflected the tax liabilities petitioner reported on his returns, plus additions to tax, interest, and collection costs. The parties were unable to resolve the matter, and Ms. Frazier issued a notice of determination sustaining respondent's Notice of Federal Tax Lien as the appropriate means of collecting petitioner's unpaid liabilities for 1992, 1998, and 2000. 2. The Petition The petition petitioner filed with this Court covered tax years 1990, 1992, 1998, 2000, 2001, and 2002. Because the notice of determination addressed only 1992, 1998, and 2000, respondent's motion to dismiss for lack of jurisdiction and to strike as to the remaining years was granted. In his petition, petitioner states: I dispute the amounts I am being billed for. Some years are correct, others the IRS claim [sic] to be self-reported income taxes but which start out with a balance due of $7,159.21. This has yet to be verified but accrues interest and penalties. During certain years I was financially eligible for an offer in compromise but could not get my case reviewed. I disagree with the determination. Discussion Section 6320 entitles a taxpayer to notice of the taxpayer's right to request a hearing after a notice of lien is filed by the Commissioner in furtherance of the collection from the taxpayer of unpaid Federal taxes. The taxpayer requesting the hearing mayPage: Previous 1 2 3 4 5 6 7 8 9 Next
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