- 4 - April 5, 2001, a Federal tax lien was filed with respect to petitioner’s unpaid income tax liabilities for the years at issue. The lien was recorded on April 17, 2001. On April 18, 2001, the Taxpayer Advocate sent a letter to petitioner explaining why his previous offers were rejected. The letter also stated petitioner needed to complete another offer containing current financial information and file it through the Taxpayer Advocate’s Office. On May 13, 2001, petitioner timely filed a Form 12153, Request for a Collection Due Process Hearing. Petitioner’s request contained his New Orleans address and telephone number. In his hearing request, he alleged the notice of tax lien filing was untimely, an offer-in-compromise was pending, and the Taxpayer Advocate had placed a hold on collection. On July 13, 2001, the Taxpayer Advocate’s Office sent another letter to petitioner expressing: “[we] have never received [your] current Form 656 or financial statements with verification.” Again, petitioner failed to work with respondent to resolve his 1992-94 tax liabilities. Petitioner became a permanent resident of Southern California later in 2001. Respondent’s Appeals Office sent a letter dated March 19, 2002, to petitioner’s New Orleans address informing him that Appeals had scheduled a conference with petitioner on March 27,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011