Laura A. Gavigan - Page 6

                                        - 5 -                                         
          Petitioner did not submit financial information on a Form 433-A,            
          stating: “With regard to Appeals considering collection                     
          alternatives, this will not be necessary.  I elect to make                  
          payment in full if a determination which is based upon                      
          requirements of law and administrative procedure shows that an              
          amount is due and owed”.                                                    
               On May 13, 2003, petitioner attended a scheduled face-to-              
          face meeting with the settlement officer.  At the hearing,                  
          petitioner requested that she be permitted to audio record her              
          hearing.  Her request was denied.                                           
               On July 9, 2003, respondent issued to petitioner a Notice of           
          Determination Concerning Collection Action(s) under Section 6320            
          and/or 6330 (notice of determination).  In the notice of                    
          determination, the settlement officer determined that it was                
          appropriate for respondent to proceed with the proposed levy to             
          collect petitioner’s tax liability.  In regard to issues                    
          discussed at the hearing, the settlement officer wrote:                     
               You stated, at the hearing, that you know of no section                
               of the Internal Revenue Code, which requires you to pay                
               the tax.  You also state that, despite admitted gross                  
               income in 1996 no authority is authorized to assess                    
               you.  A discussion of Internal Revenue Code Sections 1,                
               61 and 63 took place at the hearing. * * *                             
                        *     *     *     *     *     *     *                         
               No valid issues were raised.  Throughout this                          
               proceeding you disputed the legal basis and procedures                 
               relating to the 1996 obligation.  You have not taken a                 
               significant or positive step to resolve the 1996                       
               delinquency.  Your issues are without foundation.  No                  





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011