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9, 2004, respondent debited petitioner’s account for his taxable
year 1997 in the amount of $6 for “FEES AND COLLECTION COSTS”.
On August 16, 2004, respondent credited petitioner’s account for
that year in the amount of $853.74 to reflect a payment that
petitioner made on August 12, 2004.
Respondent issued to petitioner respective notices of
balance due with respect to petitioner’s unpaid liabilities for
1997, 1998, 1999, and 2000, as required by section 6303.
On or about July 8, 2004, respondent prepared and filed a
notice of Federal tax lien with respect to petitioner’s unpaid
liabilities for 1997, 1998, 1999, and 2000.
On July 15, 2004, respondent issued to petitioner a notice
of Federal tax lien filing and your right to a hearing (notice of
lien) with respect to petitioner’s unpaid liabilities for 1997,
1998, 1999, and 2000. On August 9, 2004, in response to the
notice of lien, petitioner filed Form 12153, Request for a
Collection Due Process Hearing (Form 12153), and requested a
hearing with respondent’s Appeals Office (Appeals Office).
Respondent’s Appeals officer (Appeals officer) held a
hearing with petitioner. Petitioner claimed, inter alia, that he
had no assets with which to pay petitioner’s unpaid liabilities
for 1997, 1998, 1999, and 2000 and that he had made certain
payments against certain of those unpaid liabilities but that
respondent did not properly credit such payments.
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Last modified: May 25, 2011