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tax lien with respect to petitioner’s taxable years 2000, 2001,
and 2002. On September 27, 2005, respondent issued to petitioner
a notice of Federal tax lien filing and your right to a hearing
(notice of tax lien) with respect to those years.
On October 27, 2005, petitioner’s authorized representative
mailed to respondent Form 12153, Request for a Collection Due
Process Hearing (petitioner’s Form 12153), and requested a
hearing with respondent’s Appeals Office (Appeals Office). In
that form, petitioner’s authorized representative indicated
disagreement with the notice of tax lien3 and stated:
TAXPAYER HASN’T FILED HIS 1999-2004 INCOME TAX RETURNS.
HE HAS ENGAGED OUR FIRM TO PREPARE SUCH INCOME TAX
RETURNS AND OBTAIN FINANCING TO LIQUIDATE HIS IRS
LIABILITIES AND REQUEST AN ABATEMENT OF PENALTIES AND
INTEREST DUE TO HIS EMOTIONAL AND PHYSICAL STATE.
AMENDED INCOME TAX RETURNS ARE REQUIRED. IT WILL TAKE
APPROXIMATELY 60 DAYS TO PREPARE SUCH AMENDED INCOME
3In petitioner’s Form 12153, petitioner’s authorized repre-
sentative indicated disagreement with not only the notice of tax
lien that respondent issued to petitioner but also certain
notices of intent to levy and your right to a hearing (notice of
intent to levy) that respondent issued to petitioner. In this
connection, Form 4340 with respect to petitioner’s taxable year
2002 indicates that on Apr. 18, 2005, respondent issued a notice
of intent to levy with respect to petitioner’s taxable year 2002
and that on May 9, 2005, respondent issued a notice of intent to
levy with respect to petitioner’s taxable years 2000 and 2001.
Petitioner’s authorized representative did not mail petitioner’s
Form 12153 until Oct. 27, 2005, which was more than 30 days after
the respective dates on which respondent issued those notices of
intent to levy. As discussed below, the notice of determination
concerning collection action(s) under section 6320 and/or 6330
(notice of determination) addresses only the notice of tax lien
and makes no determination with respect to the respective notices
of intent to levy issued with respect to petitioner’s taxable
years 2000 and 2001 and 2002.
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Last modified: November 10, 2007