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.
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