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6651(a)(1) and 6654(a) of $3,828 and $434, respectively, for
2002.
Petitioner received, but did not file a petition with
respect to, the notices of deficiency for 1999, 2000, 2001, and
2002. Respondent assessed the deficiencies along with additions
to tax and interest for 1999, 2000, 2001, and 2002 on March 22,
May 17, March 22, and December 20, 2004, respectively.
Petitioner’s assessed tax liabilities for 1996 through 2002
have not been fully paid. On March 22, 2005, respondent mailed
petitioner a Notice of Federal Tax Lien Filing and Notice of Your
Right to a Hearing Under IRC 6320 (notice of Federal tax lien),
with respect to the years at issue.
On March 28, 2005, petitioner submitted Form 12153, Request
for a Collection Due Process Hearing, in which he argued the
Internal Revenue Service did not have the authority to file a
lien and asserted other frivolous tax-protester arguments.
Petitioner’s request did not address any alternative methods of
collection.
On May 13, 2005, a hearing was held by telephone between
petitioner and respondent’s Appeals Office. On June 3, 2005,
Appeals mailed petitioner a notice of determination sustaining
the filing of the notice of Federal tax lien. The notice of
determination stated, in part:
The taxpayer has filed an appeal under * * * 6320. He
has appealed the filing of the Notice of Federal Tax
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