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C. Collection Actions
Respondent filed a Notice of Federal Tax Lien on July 15,
2002. On July 18, 2002, respondent mailed petitioners a Notice
of Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 (NFTL), regarding their unpaid 2000 taxes. Petitioners
submitted Form 12153, Request for a Collection Due Process
Hearing, to respondent indicating that they contested the filed
lien. On their request, petitioners wrote only “see return
amended pursuant to IRC 83(c)” as their reason for disagreeing
with respondent’s NFTL.
Petitioners’ request for a hearing was assigned to an
Appeals officer in Dallas, Texas. Upon petitioners’ request, the
case was transferred to respondent’s Seattle, Washington, Appeals
Office and assigned to Denise Mountjoy. On September 30, 2003,
Appeals Officer Mountjoy had a conversation with petitioners’
counsel, Mr. Isaacson, during which she declined to consider
petitioner’s request for relief because she could not consider
their underlying liability. On October 8, 2003, respondent
issued a Notice of Determination Concerning Collection Action(s),
sustaining the lien against petitioners.
Petitioner timely filed a petition for lien or levy action
with the Court on November 12, 2003. On August 19, 2004, this
case was set for trial during the January 24, 2005, Trial Session
in Seattle, Washington. On November 8, 2004, respondent moved
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Last modified: May 25, 2011