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(notice of tax lien) with respect to petitioner’s taxable years
1990 through 1992, 1994, 1996, and 2002.17 Petitioner did not
file Form 12153, Request for a Collection Due Process Hearing
(Form 12153), with respect to that notice of tax lien. See infra
note 18.
On February 7, 2005, respondent issued to petitioner a
notice of intent to levy and notice of your right to a hearing
with respect to each of petitioner’s taxable years 1990 through
1992, 1994, 1996, 1997, and 2002. (We shall refer collectively
to those notices of intent to levy as the notices of intent to
levy.)
On March 7, 2005, respondent received Form 12153 that Mr.
Silverberg submitted on behalf of petitioner (petitioner’s Form
12153). In that form, Mr. Silverberg indicated petitioner’s
disagreement with the notices of intent to levy and requested a
hearing with respondent’s Appeals Office (Appeals Office).18 Mr.
Silverberg attached a letter to petitioner’s Form 12153. In that
17The record does not indicate why respondent did not issue
to petitioner a notice of tax lien with respect to petitioner’s
taxable year 1997. As discussed below, the notice of determina-
tion concerning collection action(s) under section 6320 and/or
6330 (notice of determination) made no determination with respect
to the notice of tax lien with respect to petitioner’s taxable
years 1990 through 1992, 1994, 1996, and 2002.
18In petitioner’s Form 12153, Mr. Silverberg did not indi-
cate disagreement with the notice of tax lien filed with respect
to petitioner’s taxable years 1990 through 1992, 1994, 1996, and
2002. See supra note 17 and accompanying text.
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