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On December 16, 2002, petitioner filed an amended return
for his 1998 taxable year. On November 10, 2003, respondent
assessed additional taxes for petitioner’s 1998 taxable year of
$16,567. On October 24, 2005, the outstanding balance, including
interest and penalties, for petitioner’s 1998 taxable year was
$20,720.51.
On April 15, 2005, respondent sent petitioner and Mrs.
Waters a Notice of Federal Tax Lien Filing and Your Right to a
Hearing under IRC 6320 for taxable years 1997 and 1998. On May
23, 2005, petitioner filed a Form 12153, Request for Collection
Due Process Hearing.
By letter dated October 25, 2005, respondent’s Settlement
Officer, Mary Craca (Ms. Craca), informed petitioner that she had
been assigned to his case and set an appointment for a face-to-
face meeting in the Washington, D.C., Appeals Office at 1:00 p.m.
on November 8, 2005. Ms. Craca also stated in the letter that,
for her to consider collection alternatives, petitioner must
submit a completed Form 433-A, Collection Information Statement
for Wage Earners and Self-Employed Individuals, and 2001, 2002,
and 2003 tax returns.
On November 8, 2005, petitioner telephoned Ms. Craca and
left a message stating that he would not be able to attend the
hearing. Ms. Craca returned petitioner’s telephone call later
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