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interest. Respondent sent petitioner a Notice of Federal Tax
Lien Filing and Your Right to a Hearing Under I.R.C. 6320 (CDP
Notice), dated January 7, 2005, advising petitioner that a notice
of Federal tax lien had been filed with respect to his unpaid
liabilities for taxable years 1998, 2000, 2001, and 2002, and
that petitioner could receive a hearing with respondent’s Office
of Appeals.
On February 16, 2005, petitioner timely submitted a Form
12153, Request for a Collection Due Process Hearing. On Form
12153, petitioner states only “I DONOT [sic] UNDERSTAND!”
Petitioner did not suggest any collection alternatives.
Petitioner was not current in filing his income tax returns,
having failed to file returns for 1999, 2003, and 2004.
On June 7, 2005, Settlement Officer Suzanne Magee (Mrs.
Magee) set up a telephonic conference for June 28, 2005,
requested returns for the 1999, 2003, and 2004 tax years,
requested the collection information statement, requested proof
of payment of estimated taxes for 1999, 2003, and 2004, and
provided information on what could be discussed during the
collection due process hearing. Mrs. Magee requested that such
information be provided by July 21, 2005.
By letter dated June 17, 2005 (June 17 letter), petitioner
requested a conference at a later date. The June 17 letter also
requested a face-to-face hearing and contained frivolous
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