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Background
Respondent sent to petitioner a Final Notice - Notice of
Intent to Levy and Notice of Your Right to a Hearing and a Notice
of Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 with respect to unpaid tax that had previously been assessed
for the 1994 tax year. Petitioner timely requested a hearing
with respect to each notice.
In a letter dated August 17, 2006, acknowledging
petitioner’s hearing requests, respondent’s Appeals officer
advised petitioner that a telephonic hearing was scheduled for
September 21, 2006, at 12:30 p.m. The letter advised petitioner
that the issues raised in his hearing requests are those that
courts have determined are frivolous. However, the Appeals
officer advised petitioner that he would be allowed a face-to-
face hearing on any relevant, nonfrivolous issue, or a hearing
via correspondence, if petitioner appropriately requested such a
hearing within 14 days. The letter also advised petitioner that
if he desired to pursue alternative collection methods, he should
provide a Form 433-A, Collection Information Statement for Wage
Earners and Self-Employed Individuals, and a signed tax return
for the 2005 tax period. Petitioner did not call respondent at
the scheduled time for the hearing, nor did he indicate in a
timely fashion that such date and/or time was inconvenient.
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Last modified: November 10, 2007