-4-
informed petitioner of (1) respondent’s intention to levy under
section 6331 and (2) petitioner’s right under section 6330 to a
hearing with respondent’s Office of Appeals (Appeals). Enclosed
with the final notice was a copy of Form 12153, Request for a
Collection Due Process Hearing.
On March 13, 1999, petitioner sent to respondent the Form
12153 requesting the referenced hearing.
On August 28, 2000, Appeals officer Patrick J. Wilcox held
with petitioner a hearing under section 6330. At the hearing,
the Appeals officer provided petitioner with copies of the MFTRA-
X transcript with respect to petitioner’s income tax liabilities
for 1990 and 1991. On September 8, 2000, the Appeals officer
mailed to petitioner copies of the TXMODA transcripts for 1990
and 1991. Additionally, on September 12, 2000, the Appeals
officer mailed to petitioner two Forms 4340, Certificate of
Assessments, Payments and Other Specified Matters. The Forms
4340 were dated September 6, 2000, and were for 1990 and 1991
respectively.
On September 14, 2000, respondent issued to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 for 1990 and 1991. This notice
reflected the determination of Appeals to sustain the proposed
levy.
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Last modified: May 25, 2011