- 5 - taxes, and, on May 9, 2001, respondent issued to the trustee a notice of deficiency with respect to the trust’s 1999 Federal income tax. No petitions were filed in this Court in response to any of those notices of deficiency, and respondent properly assessed the deficiencies determined in each case. Notices On March 22, 2004, respondent sent to the Gillespies with respect to their 1999 tax year a Final Notice – Notice of Intent to Levy and Notice of Your Right to a Hearing (final notice). On March 29, respondent sent to the trustee with respect to the trust’s 1996 through 1999 tax years a final notice. On April 9, 2004, respondent sent to the Gillespies with respect to their 1996 through 1999 tax years a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 (NFTL). On that same date, respondent sent to the trustee with respect to the trust’s 1996 through 1999 tax years an NFTL. Responses and Hearing On April 27, 2004, in response to the final notice they had received, the Gillespies filed with Appeals an Internal Revenue Service (IRS) Form 12153, Request for a Collection Due Process Hearing. On the Form 12153, the Gillespies stated their disagreement with the final notice as follows: “We disagree with the determination of the taxes and additions owed, and the calculations of the amounts due, if any.” On May 13, 2004, inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007