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of (1) respondent’s intention to levy under section 6331 and
(2) petitioners’ right under section 6330 to a hearing with
respondent’s Office of Appeals (Appeals). Enclosed with the
final notice was a copy of Form 12153, Request for a Collection
Due Process Hearing.
On August 5, 2000, petitioners sent to respondent the Form
12153 requesting the referenced hearing. Petitioners attached to
the Form a request that the hearing officer have at the hearing
“the specific Code Section making me [petitioners] ‘liable’ for
the income tax at issue, along with Form 23C” and “The delegation
of authority from the Secretary authorizing such persons [IRS
employees] to impose a ‘frivolous’ penalty.” On January
10, 2001, respondent sent to petitioners a letter stating that
petitioners were precluded by section 6330(c)(2)(B) from raising
liability as an issue and that all other issues raised by
petitioners were without merit. Respondent enclosed with that
letter a transcript of petitioners’ account.
On January 30, 2001, Appeals Officer Wiley Davis held with
petitioners a hearing under section 6330. On May 8, 2001,
respondent issued to petitioners duplicate Notices of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 for 1997. These notices reflected the determination
of Appeals to sustain the proposed levy.
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Last modified: May 25, 2011