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expenses and current compliance to the taxpayer prior to issuance
of the Notice of Intent to Levy. An independent review of this
determination was also conducted per the Internal Revenue Manual
and was sustained. Sources of collection were identified prior
to issuance of the Notice of Intent to Levy. All administrative
procedures were followed.
BALANCING THE NEED FOR EFFICIENC [sic] COLLECTION WITH THE
CONCERN THAT COLLECTION IS NO MORE INTRUSIVE THAN NECESSARY
The taxpayers has [sic] been given repeated explanations and
policy guidelines relative to allowable expenses and current
compliance. Both the compliance employee and Settlement Officer
have provided the taxpayer with alternatives to the levy however
he insists on more reasonable terms. The financial information
reveals an ability to pay all the subject taxes, penalty and
interest in full by making substantial monthly payments after
giving one year to adjust his life-style. Resolving the
unsecured charge card debt and excessive housing expenses will
permit substantial payments. The compliance issue is also a
road-block to these collection alternatives at this time. Levy
activity at this time is not considered overly intrusive
considering the attempts made by the Service to resolve this
situation and lack of compliance with filing Federal Income Tax
Returns in a timely manner.
RECOMMENDATION
The Notice of Intent to Levy is sustained.
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Last modified: May 25, 2011