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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:
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Last modified: November 10, 2007