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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,
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Last modified: May 25, 2011