Mark S. & Lois A. Freme - Page 7




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          amounts with respect to petitioners’ taxable year 2003, as well             
          as interest provided by law accrued after May 31, 2004, as                  
          petitioners’ unpaid 2003 liability.)                                        
               Respondent issued to petitioners the notice and demand for             
          payment required by section 6303(a) with respect to petitioners’            
          unpaid 2003 liability.                                                      
               On June 22, 2005, respondent filed a notice of Federal tax             
          lien (tax lien filing) with respect to petitioners’ taxable years           
          1998 through 2003.  That tax lien filing showed, inter alia, no             
          amount with respect to petitioners’ taxable year 1998 under the             
          heading “Unpaid Balance of Assessment”.                                     
               On June 23, 2005, respondent issued to petitioners a notice            
          of Federal tax lien filing and your right to a hearing under IRC            
          6320 (notice of tax lien) with respect to petitioners’ taxable              
          years 1998 through 2003.  That notice of tax lien showed, inter             
          alia, zero dollars with respect to petitioners’ taxable year 1998           
          under the heading “Amount Owed”.                                            
               On July 11, 2005, in response to the notice of tax lien,               
          petitioners filed Form 12153, Request for a Collection Due                  
          Process Hearing (petitioners’ Form 12153), and requested a                  
          hearing with respondent’s Appeals Office (Appeals Office).  In              
          petitioners’ Form 12153, petitioners indicated that they did not            
          agree with the notice of tax lien, and stated: “payments have               
          been made have never recieved [sic] accounting.”                            







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