Leonard O. Parker, Jr. - Page 4

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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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