- 5 - 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 theyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011