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On December 30, 2002, the IRS sent to petitioner and her
spouse Letter 3172, Notice of Federal Tax Lien Filing and Your
Right to a Hearing Under IRC 6320, for their 1990 Federal income
tax liability. Petitioner and her spouse, through Debbie Wales,
their authorized representative, timely requested a hearing with
respect to the filing of the notice of Federal tax lien. In the
request for a hearing, it was alleged that 1991 was audited
before 1990 and was found to be “acceptable”.
The Appeals officer conducted the collection due process
hearing by telephone and correspondence with petitioner and Ms.
Wales with respect to the notice of lien filing. Other than the
existence or amount of the underlying liability, petitioner
raised no issues for consideration by the Appeals officer.
Petitioner, however, presented no evidence with respect to the
underlying tax liability.
The Appeals Office issued the notice of determination in
this case finding the filing of the Notice of Federal Tax lien to
be an appropriate collection method.
Discussion
Section 6320 entitles a taxpayer to notice of his right to
request a hearing with the IRS Office of Appeals after a notice
of lien is filed by the Commissioner in furtherance of the
collection of unpaid Federal taxes. The taxpayer requesting the
hearing may raise any relevant issue with regard to the
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