Investment Research Associates, Inc. - Page 4

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          the years in dispute).  On October 30, 2002, respondent filed a             
          Notice of Federal Tax Lien with the secretary of state for the              
          State of Florida (the Florida lien) with regard to petitioner’s             
          unpaid taxes for the years in dispute.  Petitioner did not submit           
          to respondent a request for an administrative hearing with regard           
          to the Florida lien.                                                        
               On February 24, 2003, respondent filed a Notice of Federal             
          Tax Lien with the secretary of state for the State of Illinois              
          (the Illinois lien) with regard to petitioner’s unpaid taxes for            
          the years in dispute.  On February 24, 2003, respondent mailed to           
          petitioner a Notice of Federal Tax Lien Filing and Your Right to            
          a Hearing Under IRC 6320 with regard to petitioner’s unpaid taxes           
          for the years in dispute.  On March 25, 2003, petitioner                    
          submitted to respondent’s Office of Appeals (Appeals Office) a              
          request for an administrative hearing under section 6320.                   
               The Appeals Office determined that petitioner’s request for            
          an administrative hearing was not timely and conducted a so-                
          called equivalent hearing.  Sec. 301.6320-1(i), Proced. & Admin.            
          Regs.  On August 4, 2005, respondent mailed to petitioner a                 
          decision letter for the years in dispute.  The decision letter              
          stated in pertinent part:                                                   
               Your due process hearing request was not filed within                  
               the time prescribed under Section 6320 and/or 6330.                    
               However, you received a hearing equivalent to a due                    
               process hearing except that there is no right to                       
               dispute a decision by the Appeals Office in court under                
               IRC Sections 6320 and/or 6330.                                         





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