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with the 1995 and 1996 tax liabilities of petitioners. On
November 6, 2003, respondent also issued a Notice of Federal Tax
Lien Filing and Your Right to a Hearing Under IRC 6320 to
petitioners in connection with the 1995 and 1996 tax liabilities.
On or about December 5, 2003, Renaissance Health Systems LLC
(Nominee, Transferee, or Alter-Ego, Felix K. Prakasam)3 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 petitioners’ representatives.
On June 9, 2004, respondent issued a Decision Letter
Concerning Equivalent Hearing under Section 6320 and/or 6330 of
the Internal Revenue Code (Decision Letter I) to petitioner for
tax year 1995. On July 8, 2004, petitioners mailed a petition
to this Court setting forth their disagreement with Decision
Letter I.
On June 18, 2004, respondent issued a Decision Letter
Concerning Equivalent Hearing under Section 6320 and/or 6330 of
the Internal Revenue Code (Decision Letter II) to petitioners for
tax year 1996. On July 12, 2004, petitioners filed a petition
with this Court setting forth their disagreement with Decision
Letter II.
3 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.
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Last modified: May 25, 2011