- 4 -
not timely request a hearing in response to the March 19, 2001,
notice.
III. 1995, 1996, and 1997
On November 6, 2003, respondent issued a Notice of Federal
Tax Lien Filing-Nominee, Transferee or Alter-Ego (Nominee Lien)
to Renaissance Health Systems LLC (Renaissance) in connection
with the 1995, 1996, and 1997 tax liabilities of petitioner. On
November 6, 2003, respondent also issued a Notice of Federal Tax
Lien Filing and Your Right to a Hearing Under IRC 6320 to
petitioner in connection with the 1995, 1996, and 1997 tax
liabilities.
On or about December 5, 2003, Renaissance Health Systems LLC
(Nominee, Transferee, or Alter-Ego, Lloyd A. Pragasam)2 submitted
a Form 12153, Request for a Collection Due Process Hearing,
setting forth disagreement with the filed Notice of Federal Tax
Lien. On February 25, 2004, the Appeals Office held a hearing
with petitioner’s representatives.
On June 14, 2004, respondent issued a Decision Letter
Concerning Equivalent Hearing under Section 6320 and/or 6330 of
the Internal Revenue Code to petitioner. On July 14, 2004,
petitioner mailed a petition to this Court setting forth his
disagreement with the Decision Letter.
2 In light of our resolution of the case, we need not
address respondent’s argument that this entity had no rights to
its own collection hearing or equivalent hearing.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011