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1995, 1996, 1997, 1998,7 1999, 2000, 2001, and 2002,
respectively.
F. Administrative Hearing
On May 23, 2005, petitioners submitted Form 12153, Request
for a Collection Due Process Hearing, in which they claimed the
second notice of Federal tax lien should not have been filed
because of representations made by respondent’s revenue officer
that a lien would not be filed while they were negotiating an
offer-in-compromise.
On June 24, 2005, petitioners mailed a letter to respondent,
in which they asserted that the tax liability indicated in the
second notice of Federal tax lien failed to reflect the $4,664
overpayment credit from 2004.8 On July 21, 2003, respondent’s
Appeals Office mailed petitioners a letter acknowledging receipt
of petitioners’ request for an administrative hearing.
On October 27, 2005, a face-to-face conference was held
between Settlement Officer Thomas Knauss and Oliver W. Williams
(petitioner). During the hearing, petitioner asserted that the
offer-in-compromise should not have been returned because he
provided all requested documentation, the second notice of
7 The unpaid balance for 1998 as indicated on the second
notice of Federal tax lien did not include the balance owing in
the first notice of Federal tax lien.
8 The $4,664 overpayment credit was applied to the 1998 Form
5329 10-percent additional tax liability reflected in the first
notice of Federal tax lien.
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Last modified: November 10, 2007