- 5 - Process Hearing (Form 12153). Petitioner attached the following statement to Form 12153: I. NOTICE OF INTENT TO LEVY - Explanation for Disagree- ment Income. (1) There was a failure to issue Notices of Deficiency; (2) There was a failure to generate an assessment list; (3) There was a failure of the Commissioner to certify and transmit the assessment list; (4) There was a failure to record the assessment; (5) There was a failure to provide record of assess- ment; and, (6) There was a failure to send Notice of Assessment. On May 17, 2001, the Internal Revenue Service (IRS) Appeals officer (Appeals officer) assigned to petitioner’s case sent petitioner a letter (May 17, 2001 letter) in response to peti- tioner’s Form 12153. That letter stated in pertinent part: I have received your Request for a Collection Due Process Hearing dated September 7, 2000, and I have reviewed the information in the administrative file. The assessments for both the 1992 and 1995 returns are based upon returns that were either signed by you and Mr. Armstrong (1992) or by an authorized representative because you were out of the country (1995). No liabil- ity questions exist for these two years. If you be- lieve either assessment is incorrect you should file an amended Form 1040X for these years correcting the tax liability. As part of IRC � 6330 two items that need to be ad- dressed as part of a collection due process hearing are alternative and least intrusive means of collection. In order to facilitate the resolution of your Request for a Collection Due Process Hearing, provide the following information no later than June 1, 2001. 1. A completed Form 433A, Collection Information Statement for Individuals. 2. A completed Form 433B, Collection Information Statement for Businesses (if self employed)[.] 3. Copies of your last six months bank statements.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011