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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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Last modified: November 10, 2007