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Petitioner’s CDP hearing occurred on October 24, 2003. At
the hearing petitioner asserted that he was adversely affected by
the loss of the CDP hearing request. Petitioner paid the tax
liabilities due with respect to 1997 and 1998 on November 24,
2003. On December 5, 2003, approximately 6 weeks after the
Appeals Office hearing, the Federal tax lien for the 1996, 1997,
and 1998 tax years was released.
As indicated, a notice of determination was issued on
December 30, 2003. The Appeals officer determined that
respondent’s collection action under section 6320 was proper,
that the taxes were properly assessed, and that the notices of
Federal tax liens were properly recorded. The Appeals officer
further indicated that the tax liabilities for all years in issue
were paid in full, that the notice of Federal tax lien for 1995
had been released, and that the release of lien for 1996, 1997,
and 1998 was forwarded to the Maricopa County Recorder.3
Petitioner asserts that he entered into an agreement with
respondent for the payment of his 1995 and 1996 tax liabilities,
which allowed him to make payments of principal only, permitting
a waiver of all interest and “penalties”.4 Petitioner asserts
3 As noted earlier, the 1996, 1997, and 1998 lien was
actually released on Dec. 5, 2003, prior to the issuance of the
notice of determination.
4 An addition to tax under sec. 6651(a)(2) for failure to
timely pay the tax shown as due on the 1995, 1996, 1997, and 1998
(continued...)
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