- 4 - Table 1: Unpaid Taxes by Year Tax Year Tax Due 1998 $6,577.17 1999 11,003.93 2000 5,752.52 2001 6,053.45 2002 3,260.58 Total 32,647.65 In response to the notice of Federal tax lien Filing and Your Right to a Hearing Under IRC 6320 sent to him on March 24, 2005, petitioner timely submitted a Form 12153, Request for a Collection Due Process Hearing. On September 15, 2005, after consulting with petitioner, respondent consolidated the two appeals (the appeal of the rejection of the OIC and the appeal of the Federal tax lien filing) with one Appeals Officer (AO). The AO scheduled a hearing with petitioner for October 5, 2005. Before the hearing, the AO analyzed petitioner’s financial situation and determined what expenses were allowable under Internal Revenue Manual (IRM) guidelines. Petitioner’s central complaint with the rejection of his OIC was the exclusion of his monthly credit card payments from the expenses allowed in computing his income available to pay his outstanding tax liabilities. At the face-to-face conference between petitioner and the AO on October 5, 2005, petitioner sought approval of his OIC and did not challenge the underlying tax liabilities. The AO explainedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008