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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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Last modified: May 25, 2011