- 2 -
Background
This is an appeal from respondent’s determination to uphold
the validity of a notice of Federal tax lien filed with respect
to petitioners’ 2001 unpaid income tax liability. Petitioners
resided in Henrietta, New York, when the petition was filed.
Petitioners filed their joint Federal income tax return for
2001. Respondent subsequently commenced an examination of
petitioners’ 2001 tax year and determined a deficiency in
petitioners’ income tax and an accuracy-related penalty under
section 6662. On October 27, 2004, respondent mailed petitioners
a statutory notice of deficiency.
Petitioners failed to petition this Court with respect to
the October 27, 2004, notice of deficiency. Consequently,
respondent assessed petitioners’ unpaid 2001 tax liability and
issued notice and demand for payment. Petitioners failed to
respond to respondent’s request, and on October 5, 2005,
respondent issued to petitioners a Notice of Federal Tax Lien
Filing and Your Right to a Hearing Under I.R.C. 6320.
Petitioners timely submitted a Form 12153, Request for a
Collection Due Process Hearing.
On December 21, 2005, Appeals Officer Kenneth J. Heidle
(Officer Heidle) conducted a conference with Harold Rehm (Mr.
Rehm), petitioners’ representative and 2001 tax return preparer.
However, because Officer Heidle concluded that Mr. Rehm was not
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: November 10, 2007