- 5 - notice of Federal tax lien filing and your right to a hearing under IRC 6320 (notice of tax lien) with respect to petitioners’ taxable years 2000 and 2001. On December 2, 2004, in response to the notice of tax lien, petitioners filed Form 12153 (petitioners’ Form 12153) and requested a hearing with the Appeals Office. In petitioners’ Form 12153, petitioners indicated that they did not agree with the notice of tax lien that respondent had filed with respect to petitioners’ taxable years 2000 and 2001. Petitioners attached a document to petitioners’ Form 12153. That attachment stated in pertinent part: The debt, which is represented herein, is unfair and inequitable. Extenuating circumstances exist. There is an equal amount owed to us by the IRS in the form of a credit that could satisfy this debt in full. This credit in actuality represents an over assessment of taxes. Requiring payment up front in lieu of applying the credit against the debt creates a situation that would prevent us from ever recovering the credit (overpay- ment). Also, since Mr. Miller is currently unemployed this lien seriously damages his credit and his ability to obtain suitable employment. [Reproduced literally.] On May 24, 2005, the settlement officer with the Appeals Office (settlement officer) assigned to consider petitioners’ Form 12153 with respect to the notice of tax lien relating to petitioners’ taxable years 2000 and 2001 held a telephonic conference (May 24, 2005 telephonic conference) with petitioners. During that telephonic conference, petitioners and the settlementPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011