- 4 - 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 thePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011