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1993, 1994, and 1995 of $29,347.57, $33,763.22 and $30,195.96,
respectively.
On March 24, 2004, petitioner made payments totaling $20,000
toward his 2002 tax liability.
In a letter dated July 7, 2004, respondent sent petitioner a
Final Notice--Notice of Intent to Levy and Notice of Your Right
to a Hearing (notice of intent to levy) for the outstanding 1994,
1995, and 2002 liabilities. The notice of intent to levy showed
a total of $121,218.36 in unpaid taxes, interest, and penalties.
On July 14, 2004, petitioner paid respondent a total of
$56,731.05, satisfying his 2002 tax liability.
On July 15, 2004, respondent sent petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 (NFTL). On August 11, 2004, petitioner filed a Form 12153,
Request for a Collection Due Process Hearing, with regard to the
NFTL.
Appeals Officer Lawrence Dorr was assigned to petitioner’s
case. Petitioner’s hearing consisted of an in-person meeting
with Officer Dorr on January 19, 2005, and subsequent
correspondence. During the hearing, petitioner raised the
argument that although he had violated the literal terms of the
OIC by failing to timely pay his 2002 income tax liability, his
breach was not “material” and that respondent therefore should
not have declared him in default on the OIC. Officer Dorr did
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