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In late January 2005, the Government levied against the
wages of James J. Crisan (petitioner). Petitioner immediately
contacted respondent’s Collection Division (Collections) and
began discussing payment options to satisfy the tax liabilities
for the years at issue. Collections released the levy against
petitioner’s wages and informed him that no collection action
would be taken if he and his wife continued to work towards a
payment arrangement. Collections gave petitioners until February
21, 2005, to submit financial information and arrange an
installment agreement.
February 21, 2005, was a Federal holiday. It was not until
February 23, 2005, that petitioner was able to reach Collections
by telephone to discuss the terms of an installment agreement.
The installment agreement between petitioners and respondent
became effective March 21, 2005. In accordance with the
agreement, petitioner made an initial payment of $5,000 on March
30, 2005, and was to make monthly payments of varying amounts
until the liability was paid in full.
On March 2, 2005, respondent mailed each 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. The notice of Federal tax lien advised
petitioners of an April 7, 2005, deadline to file a request for a
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Last modified: November 10, 2007