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details of petitioner’s offer. On July 29, 2003, respondent
rejected petitioner’s offer.
On September 13, 2003, respondent issued to petitioner a
Final Notice, Notice of Intent to Levy and Notice of Your Right
to a Hearing (levy notice), in which respondent announced his
intention to levy to collect petitioner’s unpaid 2000 and 2001
tax liabilities. The levy notice also advised petitioner of his
right to a hearing with respondent’s Appeals Office. Petitioner
received the levy notice on or about September 22, 2003, but he
did not request a hearing with respondent.
On or around September 17, 2003, petitioner submitted a
second offer-in-compromise. The record does not disclose the
details of petitioner’s second offer. On December 22, 2003,
respondent rejected petitioner’s second offer-in-compromise.
On March 19, 2004, petitioner submitted a third offer-in-
compromise. The record does not disclose the details of
petitioner’s third offer.
On July 14, 2004, respondent issued to petitioner a Notice
of Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 (lien notice). The lien notice informed petitioner that he
had a right to request a hearing to appeal the collection action
and to discuss optional payment methods. The lien notice also
advised petitioner how to request a hearing and how to obtain a
release of the Federal tax lien.
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Last modified: March 27, 2008