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taxable year 1980 or 1981.
On January 7, 2005, respondent released the 1980 tax lien
and the 1981 tax lien.
On or about January 19, 2005, petitioner sent a letter to
Mark W. Everson, the Commissioner of the Internal Revenue (Com-
missioner). That letter contained statements, contentions,
arguments, and/or requests that the Court finds to be frivolous
and/or groundless.
On January 26, 2005, an Appeals officer with the Appeals
Office held an Appeals Office hearing with petitioner with
respect to the notice of tax lien.
On March 2, 2005, the Appeals Office issued to petitioner a
notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). That notice
stated in pertinent part:
Summary of Determination
Appeals and the taxpayer did not reach an agreement.
No relief was given for these periods [petitioner’s
taxable years 1980, 1981, 1982, 1983, 1984, 1992, and
1997]. The filing of the Notice of Federal Tax Lien is
appropriate.
An attachment to the notice of determination (attachment to the
notice) stated in pertinent part:
SUMMARY AND RECOMMENDATION
Melvin Hassell (“Taxpayer”) requested a hearing with
Appeals under the provision of IRC 6320 as to the
appropriateness of Notice of Federal Tax Lien.
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