Hubert W.N. Chang - Page 4




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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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