Felix and Liliana P. Prakasam - Page 6

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          file a timely hearing request in response to the first Notice of            
          Federal Tax Lien filed for tax year 1995 or 1996.  Petitioners              
          argue that they did not receive the November 7, 2000, or the                
          April 24, 2002, notices, that the first notice regarding their              
          1995 and 1996 liabilities that they received was in November                
          2003, and they requested a hearing in response to that notice.              
          I.  Last Known Address                                                      
               Sections 6320(a) and 6330(a) provide in pertinent part that            
          the Secretary shall notify a person in writing of his or her                
          right to an Appeals Office hearing regarding the Secretary’s                
          filing of a notice of lien under section 6323 or the Secretary’s            
          intent to levy, respectively, by mailing the notice required by             
          section 6320(a) or section 6330(a), as the case may be, by                  
          certified or registered mail to such person at his or her last              
          known address.  The regulations under sections 6320 and 6330                
          reference section 301.6212-2, Proced. & Admin. Regs., to define             
          “last known address”.  Secs. 301.6320-1(a)(1), 301.6330-1(a)(1),            
          Proced. & Admin. Regs.  Under section 6212, in general, the                 
          Commissioner is entitled to treat the address on a taxpayer’s               
          most recent tax return as the taxpayer’s last known address,                
          unless the taxpayer has given “clear and concise notification of            
          a different address.”  Orum v. Commissioner, 123 T.C. 1, 8                  
          (2004), affd. 412 F.3d 819 (7th Cir. 2005).                                 







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