-7-
section 6651(a)(1). On or about January 28, 2004, respondent
issued to the estate a 30-day letter reflecting the proposed
adjustments. The estate paid the deficiency but disputed the
addition to tax. By letter dated February 25, 2004, the estate
protested both the addition to tax under section 6651(a)(1)
asserted with respect to the deficiency and the additions to tax
assessed upon the filing of the estate tax return (the protest).
7. Filing of a Lien and Proposal of a Levy
Respondent filed a notice of Federal tax lien on February
25, 2004. One day later, respondent issued to the estate a
Notice of Intent to Levy and Notice of Your Right to a Hearing.
On March 1, 2004, respondent sent to the estate a Notice of
Federal Tax Lien Filing and Your Right to A Hearing Under IRC
6320. On March 23, 2004, Appeals received from the estate a
request (request) for a hearing (hearing) as to both the lien
notice and the levy notice. By letter dated June 22, 2004,
Appeals Team Manager George Riter contacted the estate regarding
the request.
8. The Protest
The protest (and not the hearing) was assigned to Appeals
Officer James Christianson (Christianson). Christianson
considered both the deficiency portion of the addition to tax
under section 6651(a)(1) and the additions to tax assessed under
section 6651(a)(1) and (2). On January 20, 2005, respondent
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