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dated June 2, 2004, respondent notified petitioner that he had
received petitioner’s abatement request and requested further
information, regarding petitioner’s personal and financial
difficulties. Petitioner did not respond to respondent’s letter
or submit any additional information.
By letter dated June 26, 2004, respondent notified
petitioner of his intent to levy with respect to petitioner’s
then outstanding 1999 tax liability. That letter also advised
petitioner of his right to request an administrative hearing
with regard to respondent’s proposed levy. According to the
letter, petitioner’s outstanding 1999 tax liability, including
interest and additions to tax, totaled $18,097.61. Petitioner,
on July 20, 2004, made a timely request for an administrative
hearing. See sec. 6330(a) and (b).
Before an administrative hearing was conducted (or even
scheduled), respondent caused a Notice of Federal Tax Lien (NFTL)
to be filed on August 12, 2004, and duly notified petitioner of
the event by certified mail on August 19, 2004. Like the
proposed levy, the NFTL related to petitioner’s then outstanding
1999 tax liability. In response to respondent’s August 19, 2004,
letter notifying him about the NFTL, petitioner timely requested
an administrative hearing. See id.
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Last modified: November 10, 2007