Patricia Agnes Williams, Debbie Wales, Next Friend - Page 5

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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.                                        
               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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