- 7 -
1994, the original amount of their income tax liability for 1994-
-$19,934.61--would be reinstated. On February 7, 2003,
respondent sent petitioners a letter of default for the taxable
year 1994.
Respondent filed a Notice of Federal Tax Lien on April 29,
2004, showing $12,525.27 owed for taxable year 1994, and $332.94
owed for taxable year 2002.
Petitioners requested a Collection Due Process (CDP) Hearing
on May 11, 2004. The CDP Hearing occurred in Baltimore,
Maryland, on October 12, 2004. At the Hearing, petitioner
husband requested that the terms of the original OIC be
reinstated. He did not recommend or propose an alternative
collection means. Respondent determined that issuance of a
Notice of Federal Tax Lien would be justified, since petitioners
defaulted on the OIC when they failed to timely file and pay
their Federal income taxes for 1997, 1998, 1999, 2000, and 2001.
On November 5, 2004, respondent issued petitioners a Notice
of Determination Concerning Collection Action(s) pursuant to
section 6320 and/or 6330, in which respondent determined the
Notice of Federal Tax Lien for taxable years 1994 and 2002 to be
proper and determined that collection of the tax liabilities for
those years should proceed.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011