- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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