- 6 - An attachment to the notice of determination stated in pertinent part: Summary You filed a request for a Collection Due Process (CDP) hearing under Internal Revenue Code (IRC) § 6320 fol- lowing receipt of a Letter 3172 Notice of Federal Tax Lien Filing and Your Rights to a Hearing. A copy of the Notice of Federal Tax Lien (NFTL) and Letter 3172 were provided with the administrative file. Accord- ingly, the tax periods shown above [taxable years 2000, 2001, and 2002] were those on the NFTL sent for filing on September 27, 2005. Balances are still due as verified by computer transcripts. Your Form 12153 requesting a CDP hearing, was received on November 1, 2005. This was timely submitted as it was mailed within the 30-day period for requesting a CDP hearing. I mailed you a letter on 1/19/2006 giving you the opportunity for a hearing on 2/28/2006. On 2/28/2006 your representative * * * contacted me and requested an additional two weeks to prepare your delinquent returns and submit a collection alternative. [petitioner’s authorized representative] * * * was granted the addi- tional time. On 3/28/2006 I contacted him again for the information. He stated he had nothing to submit and requested this determination be issued. You have not filed an income tax return since 1989, The IRS requested that you file returns for 2000, 2001 and 2002 and gave you an opportunity to appeal the proposed assessments. You did not do so, therefore the underlying liability issue is precluded within Collec- tion Due Process under IRC §6330. There is no informa- tion in the file that warrants the withdrawal of the filed NFTL. The filed NFTL is the appropriate action in this case. Brief Background The CDP notice was for unpaid income tax liabilities for your 2000, 2001 and 2002 Form 1040. The returns were prepared by the IRS when you failed to file them yourself. The IRS assessed tax as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007