- 3 - 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”.Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007