Orlun K. Jones - Page 3




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          24, 2005, respondent mailed to petitioner a Notice of Federal Tax           
          Lien Filing and Your Right to a Hearing Under IRC 6320 for                  
          taxable years 1985 through 1992.  In response to this notice, on            
          February 8, 2005, petitioner submitted a Form 12153, Request for            
          a Collection Due Process Hearing, challenging the filing of the             
          Federal tax lien on the ground that “the tax assessment numbers             
          are grossly overstated”.                                                    
               On November 1, 2005, a telephonic hearing was held between             
          petitioner’s representative and respondent’s Appeals officer.               
          Petitioner submitted no offer-in-compromise or other collection             
          alternative during the hearing.                                             
               By two separate notices of determination dated May 11, 2006,           
          respondent sustained the proposed levy action and the filing of             
          the notice of Federal tax lien.2  On June 12, 2006, while                   
          residing in California, petitioner filed a timely petition for              
          review of respondent’s determinations.                                      





               2 The notices of determination indicate that in telephone              
          calls on Feb. 23 and 27, 2006, petitioner’s representative was              
          asked what petitioner would like to do with respect to collection           
          alternatives but “No meaningful response was received.”  The                
          notices of determination indicate that the Appeals officer                  
          nevertheless considered collection alternatives but concluded               
          that they were inappropriate because petitioner’s Form 433A,                
          Collection Information Statement for Individuals, was incomplete            
          and contained “numerous unexplained and seemingly contradictory             
          statements”.                                                                






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