126 T.C. No. 7 UNITED STATES TAX COURT INVESTMENT RESEARCH ASSOCIATES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16410-05L. Filed April 18, 2006. R filed a Federal tax lien in Florida (Florida lien) and mailed to P a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 (lien notice) regarding P’s unpaid taxes for 1980, 1982, 1984, 1985, 1986, 1987, 1988, 1989, and 1997 (the years in dispute). P did not submit to R a request for an administrative hearing with regard to the Florida lien. Three months later, R filed a Federal tax lien in Illinois (Illinois lien) and mailed to P a second lien notice for the years in dispute. P submitted to R’s Office of Appeals a request for an administrative hearing regarding the Illinois lien. Relying on sec. 301.6320-1(b)(1) and (2), Proced. & Admin. Regs., R’s Office of Appeals determined that P’s request for an administrative hearing was not timely because P failed to request an administrative hearing in response to the earlier Florida lien. The Office of Appeals conducted a so-called equivalent hearing and mailed to petitioner a decision letter. P filed a petition with the Court challenging R’s decision letter.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011