Ginger Harmornick - Page 8

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          17, 1994, and April 13, 1995, she cannot challenge the existence            
          or amount of her underlying tax liabilities for 1990 through 1993           
          in this collection review proceeding.  Respondent further                   
          contends that the Appeals officer’s review of Forms 4340 with               
          regard to petitioner’s account for 1990 through 1993 satisfied              
          the verification requirement imposed under section 6330(c)(1).              
               The Court issued a notice of filing to petitioner directing            
          her to file an objection, if any, to respondent’s motion.                   
          Petitioner failed to respond.  Thereafter, pursuant to notice,              
          respondent’s motion was called for hearing at the Court's motions           
          session in Washington, D.C.  Counsel for respondent appeared at             
          the hearing and presented argument in support of the pending                
          motion.  Although there was no appearance by or on behalf of                
          petitioner at the hearing, she did file a statement pursuant to             
          Rule 50(c).                                                                 
               Section 6331(a) provides that if any person liable to pay              
          any tax neglects or refuses to pay such tax within 10 days after            
          notice and demand for payment, the Secretary is authorized to               
          collect such tax by levy on the person’s property.  Section                 
          6331(d) provides that at least 30 days before enforcing                     
          collection by levy on the person's property, the Secretary is               
          obliged to provide the person with a final notice of intent to              
          levy, including notice of the administrative appeals available to           
          the person.                                                                 

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