- 6 - 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 didPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011