- 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
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