1776 Patriot Way
November 30, 2006
Internal Revenue Service
Attn: Collection Dept
Re: Karen Patriot, SSN# 123-45-6789
Dear Tax Collectors:
You filed notice of federal tax liens against me several years ago for thousands of dollars for tax years 1989, 1990, 1991, 1992, 1993, 1994 and 1995.Then you later re-filed notices of NFTL.
These liens were refiled against me several years ago and are now in the records of the courthouse in the county where I live. This creates immense embarrassment for me and also prevents me from selling any real estate.
For the tax years in question, I did not receive a notice of proposed assessment (30 day letter), the notice of deficiency (90 day letter) and my notice of my right for collection hearing. When the liens were re-filed, I was entitled to a Notice of a CDP hearing under IRC 6320. This was not sent.
IRC 6320 (a)(2) requires the IRS to notify the taxpayer in five business days of filing the notice of federal tax lien. Your agency did not send me a copy of the NFTL within five days. Further, your agency did not send me a copy of the re-filed NFTL within five days, as the law requires. Therefore, the liens and the re-filed liens are invalid.
IRC 6320 also requires that you send me a CDPH notice within five days of the filing a NFTL. This was not done and therefore the liens are invalid.
IRC 6320 further requires that when you re-file a FTL, you must send me a CDPH notice within five days. If the CDPH notice is not sent within five days of the re-filing of the NFTL, then the lien is invalid.
I hereby request that you sent me all copies pertaining to me for the tax years listed above, for the transcripts or the below listed documents:
1. The Notice of Deficiency,
2. Notice of Proposed Assessment (by whatever name)
3. Notice & Demand Letter, form 17-A
4. The Summary Record of Assessment Form, Form 23-C, the RACS Report
5. Form 4340, Certificate of Assessments & Payments.
I request collection alternatives including OIC and payment schedule. Collection actions are inappropriate. Procedural defects by Internal Revenue Service exist. I want to see copies of the 90-day letter, Notice and Demand letter (Form 17-A), also Summary Record of Assessment (Form 23-C) or replacement form, RACS Report and my form 4340 "Certificate of Assessment and Payments" and proof that they were sent. Please produce and provide proof that I received the Notice of Deficiency and the Notice & Demand letter. I contest the existence or the amount of the tax because I did not receive a Notice of Deficiency. I will also request proof of verification from the Secretary that all applicable law and administrative procedures have been met pursuant to IRC § 6330. I am also notifying the Service of my intention to make an audio recording of the hearing pursuant to IRC § 7521.