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June 28, 1996; the proceeding filed on November 26, 1997, was
closed May 12, 1998; and the proceeding filed on June 30, 1998,
was closed October 27, 1998.
In 1999, petitioner filed two Forms 656, Offer-in-
Compromise, to settle the 1992-94 tax liabilities. The first
offer filed on February 18, 1999, was rejected on June 6, 1999,
after petitioner failed to respond to respondent’s request for
verifiable financial statements. The second offer, filed August
10, 1999, was rejected on September 26, 2000, because petitioner
again failed to provide necessary financial information and
failed to provide an original signature on the Form 656.
On March 21, 2001, respondent’s Automatic Collection Service
(ACS) requested an NFTL. On March 29, 2001, an NFTL was prepared
which was filed on April 5, 2001, by respondent with the New
Orleans Parish Recorder’s Office. Petitioner had no offer-in-
compromise in effect or pending at the time the NFTL was filed.
On April 5, 2001, the New Orleans Taxpayer Advocate Services
Office (Taxpayer Advocate) told petitioner a 45-day “hold” would
be placed on all collection actions to allow petitioner to submit
another offer-in-compromise.
On April 11, 2001, respondent timely sent, via certified
mail, a Notice of Federal Tax Lien Filing and Your Right to a
Hearing Under IRC 6320, to petitioner regarding his unpaid income
tax liabilities for the years at issue. The Notice indicated on
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