Neil Rabinowitz - Page 3

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               Petitioner timely filed a petition under section                       
          6330(d)(1)(A) for review of respondent’s determination to proceed           
          with the collection of petitioner’s 1996 and 1997 Federal income            
          tax liabilities.  The issue is whether the refusal by the Appeals           
          Office to release or withdraw a Federal tax lien constituted an             
          abuse of discretion.  At the time the petition was filed                    
          petitioner resided in Pikesville, Maryland.                                 
               The facts are as follows.  Respondent assessed tax                     
          liabilities for the taxable years 1996 and 1997 and, on December            
          28, 2004, filed a Federal tax lien showing the balance due.  On             
          December 29, 2004, respondent notified petitioner that the tax              
          lien had been filed.  Petitioner requested a hearing to have the            
          tax lien removed and suggested that a compromise was appropriate.           
          Petitioner, however, did not submit information concerning an               
          offer-in-compromise.  The Appeals Office determined that the                
          filing of the tax lien was appropriate and the least intrusive              
          collection means of protecting the Government’s interest.                   
          Petitioner appeals.                                                         
               After the filing of a notice of Federal tax lien, a taxpayer           
          is entitled to notice and an opportunity for a hearing before an            
          impartial officer of respondent’s Office of Appeals.  Secs.                 
          6320(a) and (b), 6330(b)(3).  If a taxpayer requests a hearing,             

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