§66721

Crawford, a notice of the filing of a Notice of Federal Tax Lien (NFTL) seeking to collect unpaid section 66721 trust fund recovery penalty (TFRP) liabilities for the tax periods ending September 30 and December 31, 2018.2 Mr.

OPINION ` .GOEKE, Jude : This case was commenced in response to a notice of determination concerning collection action sustaining a notice of Federal tax lien and a proposed levy with respect-to section 66721,civil penalties for three calendar quarters during 2006 and income taxes for>.years,2002 through 2005 .

rt lacks jurisdiction because respondent issued no notice of determinati n to petitioner for the taxable years 1985, 1986, 1995, 1997, 998, or 1999 (years in issue) or with respect to petitioner's out tanding liabilities SERVED MAY -5 20M - 2 - for section 66721 trust fund recovery penalties for the tax periods ending March 30, June 30, or September 30, 2002 (penalty periods in issue ; collectively periods in issue) .1 Petitioner counters that he was improperly denied a collection hearing under

On June 29, 1998, respondent assessed against petitioner a trust fund recovery penalty under section 66721 of $37,560 .77 that was attributable to the respective unpaid Federal tax liabilities of New Wave Communications, Inc ., for the periods 'All section references are to the Internal Revenue Code in effect at all relevant times .