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On August 31, 2001, respondent sent the Boyers a Notice of
Intent to Levy under Section 6331(d) relating to their unpaid
1986 and 1987 tax liabilities. The Boyers timely filed Form
12153, Request for a Collection Due Process Hearing. In their
request, the Boyers raised two issues. First, the Boyers
contended that they had no outstanding tax liability for 1986 or
1987 because the RFTL showed that their outstanding tax liability
was either paid or made unenforceable. Second, the Boyers
contended that the statutory period for collection had expired
for both the 1986 and 1987 tax liabilities. The Boyers did not
raise any spousal defenses or offer collection alternatives.
An Appeals officer wrote a letter to the Boyers dated
March 7, 2002, and explained that, although the transcripts of
their account showed that the lien for 1986 was released as
reflected by the RFTL, the lien for 1986 was released
prematurely. The Appeals officer further explained that the 1986
liability remained due and owing because the Boyers failed to
make all required payments under the 1986 installment agreement.
The Appeals officer also noted that the RFTL related solely to
the 1986 liability, not the 1987 liability. As with the 1986
liability, the balance of the 1987 liability remained due and
owing.
Regarding the Boyers’ argument that the collection period
had expired, the Appeals officer reminded the Boyers that they
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