Shirley Renee Burton - Page 4

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          those unpaid liabilities.                                                   
               On or about July 25, 2001, in response to the notice of tax            
          lien and the notice of intent to levy, petitioner filed Form                
          12153, Request for a Collection Due Process Hearing (Form 12153),           
          and requested a hearing with respondent’s Appeals Office (Appeals           
          Office).                                                                    
               On February 12, 2002, a settlement officer with respondent’s           
          Appeals Office (settlement officer) held a telephonic Appeals               
          Office hearing with petitioner with respect to the notice of tax            
          lien and notice of intent to levy.  During the telephonic Appeals           
          Office hearing, the settlement officer relied on a transcript of            
          petitioner’s account with respect to each of her taxable years              
          1988 and 1989.                                                              
               On May 2, 2002, the Appeals Office issued to petitioner a              
          notice of determination concerning collection action(s) under               
          section 6320 and/or 6330 (notice of determination).  An attach-             
          ment to the notice of determination stated in pertinent part:               
               ISSUES RAISED IN APPEAL                                                
               The under-lying liability was challenged on the Form                   
               12153.  The taxpayer also stated she did not own the                   
               property located at the address listed on the Notice of                
               Federal Tax Lien. * * *                                                
               A telephone conference was held with the taxpayer on                   
               2/12/2002.  She stated she did not feel the figures                    
               reflected on the lien or notice were correct because                   
               she did not materially participate in the examination                  
               of the subject returns.  In addition she stated she was                
               unable to pay any amount due because she did not have                  
               steady income.                                                         





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