Filed July 7, 2017
26 U.S.C. §§ 6320(c) and 6330(c)(2)(B). Within thirty days of the IRS Office of Appeals’ determination in connection with a collection due process hearing under section 6320 or 6330, the taxpayer may seek judicial review of the determination by appealing the determination to the United States Tax Court. 26 U.S.C. §§ 6320(c) and 6330(d)(1). As noted on the 2009 and 2010 IRS Account Transcripts, collection due process notices of intent to levy and collection due process notices of lien filing were previously issued to Vadym Huzenko and Saida Mamedova with respect the 2009 and the 2010 tax years.
Filed May 12, 2017
Amd. Compl. ¶¶ 2, 6. At some unspecified time, the plaintiff filed requests for collection due process hearings, presumably under 26 U.S.C. § 6320 or § 6330, as to her 2003, 2005, 2006, and 2007 tax years.
Filed February 27, 2014
A, 9A). On May 7, 2013, the IRS sent Vidurek a “Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320,” which indicated a federal tax lien had been filed with the Dutchess County Clerk in the amount of $124,762.43. 5 Case 7:13-cv-04476-VB Document 38 Filed 02/27/14 Page 5 of 24 Plaintiffs allege the IRS subjected Vidurek to heightened scrutiny in connection with the above tax assessment and collection actions because Vidurek is a Tea Party organizer, and IRS agents “singled [him] out for political reasons, with intent to destroy [his] life without reason, court order, consent, jurisdiction, or authority.”