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petitioner’s returns plus statutory additions to tax as follows.1
Additions to Tax
Year Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654
1996 $933.07 $308.52 $217.00
1997 781.65 243.18 186.13
1998 1,611.45 429.72 183.77
1999 519.75 --- 100.00
On April 14, 2005, respondent filed a notice of Federal tax
lien against petitioner for income taxes for 1996, 1997, 1998,
and 1999. On April 15, 2005, respondent sent to petitioner a
Notice of Federal Tax Lien Filing and Your Right to a Hearing
Under IRC 6320 for the years in issue.
On May 23, 2005, petitioner filed a timely Form 12153,
Request for a Collection Due Process Hearing, for the years in
issue. The hearing was conducted via telephone and written
correspondence with Settlement Officer Martin Splinter. On
September 13, 2005, the Appeals Office issued to petitioner a
notice of determination sustaining respondent’s filing of the
Federal tax lien to collect petitioner’s unpaid taxes for the
years in issue.
Discussion
Section 6320 entitles a taxpayer to notice of the taxpayer’s
right to request a hearing after a notice of lien is filed by the
1After the tax and additions to tax were assessed for each
year, petitioner subsequently made payments on his tax
liabilities (tax, interest, additions to tax combined) for each
of the years in issue. Therefore, the amount of the outstanding
balance attributable to the additions to tax has yet to be
determined.
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Last modified: May 25, 2011