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On June 17, 1996, respondent mailed to petitioner at the
Rochester, New York, address that petitioner had used on his tax
returns for the years 1990 through 1993 separate notices of
intent to levy with respect to the liabilities assessed for 1990
through 1993. The Postal Service forwarded the notices to
petitioner’s then-current address in Lewiston, New York.
On December 29, 2000, respondent mailed to petitioner a
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing Under I.R.C. 6330 (levy notice) with respect to
petitioner’s income tax liabilities for 1990 through 1993.
On August 8, 2002, respondent filed a notice of federal tax
lien for petitioner’s assessed liabilities for the years 1990
through 1993.
On August 12, 2002, respondent mailed to petitioner a Letter
3172, Notice of Federal Tax Lien Filing and Your Right to a
Hearing Under I.R.C. 6320, for petitioner’s assessed income tax
liabilities for the years 1990 through 1993. On September 11,
2002, petitioner submitted to respondent a request for a hearing
for the lien filing and the proposed levy action. On or about
March 20, 2003, petitioner submitted to respondent’s Appeals
Office an amendment to his September 11, 2002, request for a
hearing.
On April 24, 2003, respondent’s Greensboro, North Carolina
Appeals Office issued to petitioner a notice of determination
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Last modified: November 10, 2007