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Respondent issued notices of final partnership
administrative adjustments (FPAAs) to SGE 84-3 for its 1984
through 1986 taxable years.6 After completion of the
partnership-level proceedings, respondent sent petitioners a Form
4549A-CG, Income Tax Examination Changes, reflecting changes made
for petitioners’ 1981 through 1986 tax years. Respondent
determined deficiencies in petitioners’ income tax of $10,731,
$7,001, $5,552, $2,641, $5,463, and $5,268, respectively.
On November 22, 2001, respondent issued petitioners a Notice
of Federal Tax Lien and Your Right to a Hearing Under IRC 6320
(notice of lien). The notice of lien informed petitioners that a
Federal tax lien had been filed to secure payment of their
outstanding tax liabilities for 1981 through 1986.
On December 21, 2001, petitioners submitted a Form 12153,
Request for a Collection Due Process Hearing. Petitioners argued
that the Federal tax lien was inappropriate and caused them
financial hardship.
On October 31, 2003, petitioners’ case was assigned to
Settlement Officer Linda Cochran (Ms. Cochran). Ms. Cochran
scheduled petitioners’ section 6330 hearing for March 23, 2004.
During the hearing, petitioners’ representative, Terri A. Merriam
(Ms. Merriam), requested additional time to submit information.
6 The FPAAs and other information specific to SGE 84-3’s
partnership-level proceedings are not in the record.
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Last modified: May 25, 2011