-4-
Petitioner agreed with this date for the hearing by letter sent
back to the Appeals officer on December 13, 1999.
On January 6, 2000, the Appeals officer held with petitioner
the requisite hearing under section 6330. At the hearing, the
Appeals officer attempted to discuss with petitioner his
underlying tax liability for 1985. Petitioner stated that he had
no tax liability for 1985 and refused to answer any questions
and/or provide additional information or documentation with
respect to that year.
On September 8, 2000, respondent issued to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 for 1985 and 1986. This notice
reflected the determination of Appeals to sustain the proposed
levy.
OPINION
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 may 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 must provide the person with a
final notice of intent to levy, including notice of the
administrative appeals available to the person.
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