Anthony J. Kadillak - Page 12

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          memorandum by the IRS regarding the issues surrounding                      
          petitioner’s stock acquisitions.                                            
               On September 4, 2003, respondent mailed to petitioner a                
          Final Notice of Intent to Levy with respect to petitioner’s 2001            
          tax liability.  Petitioner’s counsel, Mr. Isaacson, wrote to                
          respondent and requested an administrative hearing.                         
               Appeals Officer Lawrence Dorr conducted a telephonic hearing           
          with Mr. Isaacson on December 3 and 5, 2003.  Mr. Dorr declined             
          to consider petitioner’s request for relief and issued Notices of           
          Determination Concerning Collection Actions for the years at                
          issue on January 15, 2004, and February 5, 2004, respectively.              
          In the determination, Mr. Dorr found “there was no mechanism in             
          the Collection Due Process venue for withholding collection in              
          this circumstance”.  Mr. Dorr did not review the underlying                 
          liability for the years at issue.                                           
               Petitioner timely filed a petition for lien or levy action             
          with the Court on February 18, 2004.  On August 19, 2004, this              
          case was set for trial during the January 24, 2005, Trial Session           
          in Seattle, Washington.  On October 27, 2004, respondent moved              
          for a continuance and remand.  On December 8, 2004, the Court               
          retained jurisdiction and remanded this case to respondent’s                
          Appeals Office for another administrative hearing to consider               
          petitioner’s underlying tax liabilities for the years at issue.             







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