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wanted to pay the outstanding tax liabilities for 1995 and 1996.
At some point, petitioner and respondent entered into an
installment agreement. The record does not reflect the terms of
the agreement. Petitioner made four separate payments during
1998, totaling $550, which were applied to his 1995 tax
liability. Petitioner apparently defaulted on the installment
agreement on May 10, 1999.
1997 and 1998
Petitioner’s tax liabilities for 1997 and 1998 were assessed
in amounts as reported by petitioner and his wife on the
respective returns. Petitioner made a payment of $617.39 when
the 1997 tax return was filed. Petitioner made an additional
payment of $350 with respect to the 1997 tax liability on June
13, 1998. Petitioner made a payment of $1,584.97 when the 1998
tax return was filed. As of December 7, 2000, there were
outstanding balances due on both the 1997 and the 1998 returns as
filed.
Collection History
On December 7, 2000, respondent filed two notices of Federal
tax liens for assessments made for all tax years in question. On
December 12, 2000, respondent sent by certified mail to
petitioner, a Notice of Federal Tax Lien Filing and Your Right to
a Hearing Under IRC 6320 (the 3172 Letter). On January 5, 2001,
petitioner timely filed a Form 12153, Request for a Collection
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