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PLEASE RESPOND IMMEDIATELY
Your federal tax is still not paid. We previously
asked you to pay this, but we still haven’t received
your payment. This letter is your notice of our intent
to levy under Internal Revenue Code (IRC) Section 6331
and your right to receive Appeals consideration under
IRC Section 6330.
We may file a Notice of Federal Tax Lien at any
time to protect the government’s interest. A lien is a
public notice to your creditors that the government has
a right to your current assets, including any assets
you acquire after we file the lien.
If you don’t pay the amount you owe, make
alternative arrangements to pay, or request Appeals
consideration within 30 days from the date of this
letter, we may take your property, or rights to
property, such as real estate, automobiles, business
assets, bank accounts, wages, commissions, and other
income. We’ve enclosed Publication 594 with more
information, Publication 1660 explaining your right to
appeal, and Form 12150 to request a Collection Due
Process Hearing with Appeals.
Petitioner did not request a collection due process hearing with
Appeals within 30 days of the issuance of the above notice.
Respondent thereafter initiated enforced collection by way of
levy.
In addition to the notice regarding a taxpayer’s right to a
collection due process hearing pursuant to section 6330,
respondent also provides Form 9423, Collection Appeal Request,
for taxpayers to make requests for Appeals review of collection
action under respondent’s Collection Appeals Program (CAP). CAP
is an administrative review program not required by statute. See
5 Administration, Internal Revenue Manual (CCH), sec. 9.4, at
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Last modified: May 25, 2011