Gary and Cynthia Stein - Page 8

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          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.                                                 









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