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interest in the taxpayers’ property and potentially
collecting the unpaid liability.
In response to the notice of determination, petitioners
timely filed their petition with this Court on February 9, 2006.
OPINION
I. Notices of Federal Tax Lien
The record indicates there were two separate notices of
Federal tax lien filed with respect to income tax liabilities in
1998. The first notice of Federal tax lien was filed with
respect to the 1998 Form 5329 10-percent additional tax
liability, and the second notice of Federal tax lien was filed
with respect to the income tax liability for 1998 other than the
10-percent additional tax. The second notice of Federal tax lien
did not include the 1998 Form 5329 10-percent additional income
tax liability.
Petitioners concede this Court lacks jurisdiction over the
unpaid 1998 10-percent additional tax liability because they did
not timely submit a request for an administrative hearing with
respect to the first notice of Federal tax lien. See sec.
6320(b)(1); Orum v. Commissioner, 123 T.C. 1, 7-8 (2004), affd.
412 F.2d 819 (7th Cir. 2005).
Petitioners timely submitted a request for an administrative
hearing with respect to the second notice of Federal tax lien.
See sec. 6320(b)(1). Although the first and second notices of
Federal tax lien include a 1998 income tax liability, they cover
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