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F. Administrative Collection Matters
On January 29, 1999, respondent mailed a final notice of
intent to levy to petitioner. See sec. 6331. The notice states
that petitioner owes taxes, interest, and penalties for the years
and in the amounts as follows:
Year Amount
1980 $ 793,308.52
1981 1,632,232.54
1982 278,290.41
1983 1,278,878.58
1984 175,098.63
1985 404,236.97
1986 196,256.57
The notice also states that respondent is preparing to collect
these amounts and that petitioner would be given 30 days to
request an Appeals Office hearing.
Petitioner timely requested a hearing with respondent's
Appeals Office. In particular, petitioner argued that “the time
for making an assessment for all the periods listed on your
'NOTICE OF INTENT TO LEVY' was negated on May 8, 1987".
On September 29, 1999, the Appeals Office issued a Notice of
Determination Concerning Collection Actions to petitioner stating
that respondent would proceed with collection. The determination
letter makes reference to petitioner's challenge to the validity
of the assessments and states that, because petitioner had an
earlier opportunity to dispute the underlying tax liabilities,
that issue would not be addressed by the Appeals Office.
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Last modified: May 25, 2011