- 4 - 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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011