Stephen Daryl Royal - Page 3

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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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