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petitioners reported tax on those returns, petitioners did not
enclose full payment with any of their returns.
Upon receipt of petitioners’ returns, respondent assessed
the tax reported thereon, as well as applicable penalties and
statutory interest, and sent petitioners so-called statutory
notices of balance due, i.e., notice and demand for payment. See
sec. 6303(a). Petitioners did not immediately pay the
outstanding liabilities.2
By letter dated February 16, 2006, respondent sent to
petitioners a Notice of Federal Tax Lien Filing and Your Right to
a Hearing Under IRC 6320 (lien notice). The lien notice
referenced a notice of Federal tax lien filed by respondent with
the Campbell County Clerk in Gillette, Wyoming, regarding
petitioners’ outstanding liabilities for 1995, 1998, 2002, and
2003.
The lien notice included the following statements:
You have a right to request a hearing with us to appeal
this collection action and to discuss your payment
method options. To explain the different collection
appeal procedures available to you, we’ve enclosed
Publication 1660, Collection Appeal Rights.
If you want to request a hearing, please complete the
enclosed form 12153, Request for a Collection Due
Process Hearing and mail it to:
2 Subsequently, for 1995, respondent determined a modest
deficiency in, and addition for late filing to, petitioners’
income tax. Upon default of the notice of deficiency, respondent
assessed the determined liability.
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Last modified: November 10, 2007