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On November 7, 2000, respondent sent to petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320. Petitioner did not timely request a hearing with respect
to this notice.
II. 1996
On September 29, 2000, respondent sent petitioners a notice
of deficiency addressed to petitioners at their last known
address, P.O. Box 1659, Loma Linda, CA 92354-1659, determining
petitioners owed an income tax deficiency of $468,849 and a
penalty under section 6662(a) in the amount of $93,770 for the
taxable year 1996.
Petitioners did not respond to the notice of deficiency by
petitioning the Tax Court within 90 days from September 29, 2000.
On April 19, 2002, respondent filed a Notice of Federal Tax
Lien with respect to petitioners concerning the 1996 tax year.
On April 24, 2002, respondent issued to petitioners a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 with respect to the 1996 tax year. Petitioners did not
timely request a hearing in response to the April 24, 2002,
notice.
III. 1995 and 1996
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
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