- 5 -
On October 6, 2003, respondent sent petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 (the notice of lien) for the taxable years 1994, 1995, 1996,
1997, and 1998. Petitioner timely submitted to respondent a Form
12153, Request for a Collection Due Process Hearing. Petitioner
stated in this request that he did not owe the amounts listed in
the notice of lien. He did not raise a spousal defense or offer
collection alternatives.
Respondent’s Appeals officer and petitioner had a face-to-
face hearing on March 8, 2004, and also exchanged subsequent
correspondence. A narrative of what took place at the
administrative hearing was not made part of the record. On April
8, 2004, respondent issued to petitioner a notice of
determination, which stated that the Appeals Office had
determined that the notice of lien filing was appropriate. On
May 3, 2004, petitioner filed with the Court a petition for lien
or levy action seeking review of respondent’s notice of
determination.
3(...continued)
credits totaling $1,860, that amount is not reflected on
petitioner’s tax return, the Form 1099-R, Distributions From
Pensions, Annuities, Retirement or Profit-Sharing, IRAs,
Insurance Contracts, etc., or respondent’s Form 4340, Certificate
of Assessments, Payments, and Other Specified Matters. These
discrepancies have not been explained. However, the notice of
lien reflects the lower amount and appears consistent with the
Form 4340. Accordingly, we do not need to consider this matter
any further.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011