- 5 - petitioner notified of that request and respondent’s consideration thereof or given an opportunity to participate in any of the administrative proceedings relating thereto. Sometime after January 19, 1999, respondent notified peti- tioner of his right to a hearing (Appeals Office hearing) at which he would be able to contest a proposed collection action against him with respect to the unpaid portion of the assessed 1990 tax deficiency. On May 24, 1999, after the North-South Carolina Appeals Office of the Internal Revenue Service (Appeals Office) held the Appeals Office hearing that petitioner had requested, the Appeals Office issued to petitioner a “NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330" (notice of determination). The notice of determination contained the following summary of the matters that were considered at peti- tioner’s Appeals Office hearing: Matters Considered The requirements of law and administrative procedures: whether the Service met its statutory and administra- tive requirements prior to levy. The relevant issues: whether Mr. Miller’s claim for “innocent spouse” relief could now be considered. The intrusiveness of the collection action or the proposed collection action: whether Mr. Miller’s situa- tion warranted forbearance of the collection action until his claim could be considered. The matter considered by the Appeals Office relating to “Mr.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011