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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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Last modified: November 10, 2007