Jan L. Ashlock - Page 4




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          of her cumulative total $44,383 outstanding Federal income tax              
          liabilities for 1996, 2000, 2001, 2002, and 2003.  With her OIC             
          petitioner submitted to respondent a Form 433-A, Collection                 
          Information Statement for Wage Earners and Self-Employed                    
          Individuals, and a Form 433-B, Collection Information Statement             
          for Businesses.  Petitioner did not include any information about           
          several assets––specifically, she submitted no information about            
          the Michigan property.                                                      
               On August 21, 2004, petitioner sold a 1996 Pontiac Firebird            
          to a third party for $5,250.                                                
               On February 22, 2005, respondent filed with Washington                 
          County, Oregon, a notice of Federal tax lien relating to                    
          petitioner’s outstanding 1996, 2000, 2001, 2002, and 2003 Federal           
          income tax liabilities.                                                     
               On March 3, 2005, respondent mailed to petitioner a notice             
          of Federal tax lien filing in which petitioner’s appeal rights              
          under section 6320 were explained.                                          
               On April 3, 2005, petitioner filed with respondent a                   
          Form 12153, Request for a Collection Due Process Hearing.                   
               During the Appeals Office collection hearing that ensued               
          under section 6320 among petitioner, petitioner’s                           
          representatives, and respondent’s Appeals officer, respondent’s             
          Appeals officer reviewed additional documentation which was                 
          submitted relating to petitioner’s financial condition.                     







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