Terri Armstrong - Page 5




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          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.                     





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