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On February 22, 2005, the Appeals Office issued to peti-
tioner a notice of determination. The notice of determination
stated in pertinent part: “The determination of Appeals is that
the filing of the notice of federal tax lien was appropriate and
is sustained.” An attachment to the notice of determination
stated in pertinent part:
SUMMARY AND RECOMMENDATION
* * * * * * *
The filing of the Notice of Federal Tax Lien was appro-
priate and is sustained for all of the periods listed
above [1997, 1998, 1999, and 2000].
* * * * * * *
DISCUSSION AND ANALYSIS
Verification of Legal and Procedural Requirements
The basic requirements before the IRS may file a notice
of federal tax lien include providing the taxpayer with
a notice that the tax is due, and the taxpayer’s ne-
glect or refusal to pay. The IRS must notify the
taxpayer of their right to a hearing before Appeals
after filing the notice of tax lien. With the best
information available, the requirements of various
applicable law and administrative procedures have been
met. The taxpayer was provided an opportunity to
present any relevant issues regarding the unpaid tax
and proposed collection action. The Settlement Officer
named above has had no prior involvement with respect
to these liabilities.
Related Issues Presented by the Taxpayer
A telephonic hearing was held on December 14, 2004.
You were advised that the decision to file a notice of
federal tax lien is not based solely on your available
assets or your ability to pay. Based on the amount of
your tax liability and your refusal or neglect to pay
the filing of the notice of federal tax was appropriate
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Last modified: May 25, 2011