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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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