Eryck C. Aston - Page 3

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          amount owed (including unpaid taxes, penalties, and interest) for           
          1987, 1988, 1989, and 1992 as of the date of the collection                 
          notice as $1,522,588.25.                                                    
               On March 17, 2000, petitioner sent respondent a Request for            
          a Collection Due Process Hearing for 1987, 1988, 1989, and 1992             
          (hearing request).                                                          
               Appeals Officer Keith Fessenden was assigned to petitioner’s           
          case.  Appeals Officer Fessenden sent petitioner two letters                
          scheduling a telephone hearing with petitioner.  Petitioner sent            
          Appeals Officer Fessenden a letter stating that he (petitioner)             
          did not have a phone.  In this letter, petitioner did not raise             
          any collection alternatives; he raised frivolous and groundless             
          arguments regarding his underlying tax liabilities.                         
               On June 8, 2000, respondent sent petitioner a Notice of                
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 (notice of determination) for 1987, 1988, 1989, and             
          1992 concluding that respondent could proceed with the proposed             
          collection action because “the proposed collection action                   
          balances the need for efficient collection of taxes with * * *              
          [petitioner’s] legitimate concern that any collection action be             
          no more intrusive than necessary.”                                          











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