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discuss collection alternatives.
E. Respondent’s Notices of Determination
On April 2, 2001, respondent’s Appeals Office issued to
petitioner separate Notices of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 with regard
to his tax liabilities for 1993 through 1997. In the notices,
the Appeals Office stated that respondent’s determination to
proceed with collection by way of levy should be sustained and
that the filing of the notices of Federal tax lien was
appropriate.
Also on April 2, 2001, respondent’s Appeals Office issued to
petitioner Ciao Newman a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 with regard
to her tax liabilities for 1995 through 1997. In the notice, the
Appeals Office stated that respondent’s determination to proceed
with collection by way of levy should be sustained and that the
filing of the notice of Federal tax lien was appropriate.
F. Petitioners’ Petition and Motion To Dismiss
On April 30, 2001, petitioners filed with the Court a
Petition for Lien or Levy Action seeking review of respondent’s
notices of determination.2 The petition includes the following
allegations: (1) The Appeals officer failed to obtain
2 At the time that the petition was filed, petitioners
resided in Reno, Nevada.
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