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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 settlement
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