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Petitioner in the Form 12153 provided the following explanation
of his disagreement with the notice of levy: “IRS USED ‘GUESSES’
FOR TAXPAYER’S TAX LIABILITIES FOR 12-31-89, 12-31-90, 12-31-91.
IRS IS REQUIRED TO PROVE INCOME. REQUEST HEARING OR ABATEMENT OF
TAXES, PENALTIES, INTEREST & CHARGES.” 1
After a period of correspondence between the parties, a
letter dated July 12, 2000, from Appeals Officer Steve Millang to
petitioner’s representative extended an invitation for a face-to-
face conference:
If you wish to have an Appeals hearing at my
office, you can meet with me on:
Monday - July 31, 2000 @ 9:30 a.m.
If this time and date are inconvenient, please
contact me to reschedule a mutually convenient Appeals
conference.
Ultimately, however, it appears that the hearing was conducted
solely through telephone contact and written correspondence.
Copies of letters in the record reveal that petitioner asserted
he did not receive sufficient income during the 1989 to 1991
period to necessitate the filing of returns or the paying of
1 Petitioner in the Form 12153 also made a very similar
statement registering disagreement with a “Filed Notice of
Federal Tax Lien”. However, a notice of Federal tax lien filing
was not issued to petitioner because the relevant lien was filed
in 1996, prior to enactment of sec. 6320 and the corresponding
requirement for notice to taxpayers of such agency action.
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