- 18 - Attachment to Letter 3193 Date of Notice of Tax Form / Type Tax Period Federal Tax Lien * * * * * * * 1040 12-31-1995 11-07-2003 1040 12-31-1996 11-07-2003 1040 12-31-1997 11-07-2003 * * * * * * * The IRS received from you Form 12153, postmarked 11-22- 2003. This is a request for a Collection Due Process Hearing. You filed this form in response to the Col- lection Department’s recordation of Notices of Federal Tax Lien against you relative to the above listed liabilities. The statutes for collection of these liabilities were suspended during the hearing process because your request for a hearing was mailed prior to the deadline for timely filing as provided for in IRC section 6330. * * * The Settlement Officer in this case had no prior in- volvement with the liabilities in question. Verification that Law and Procedure were Followed Information in the administrative case file and related computer records shows that the IRS followed law and procedure in this case. * * * The assessments in ques- tion were properly made under IRC section 6201, and notice and demand was sent to you as per IRC section 6303. You did not pay the liabilities. The IRS gave you additional opportunities to pay the balances due voluntarily, but you failed to do so. The Collection Department recorded the liens to protect the govern- ment’s interest. Relevant Issues Raised by the Taxpayer On the Form 12153 you state “Not Self Employed IRC Sec. 3403 and 3102(b).” The Federal Tax Lien will not be released until the full balances of all the tax years involved are paid in full. At your hearing it was discussed that the equity in * * * [Ms. Latos’ resi-Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: November 10, 2007