- 8 - 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). Discussion 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011