- 5 -
The Settlement Officer provided details concerning the
1988 and 1989 tax years in that she did provide the
examiner with information that was used to adjust the
calculation of tax, penalty and interest. The Statu-
tory Notices of Deficiency were mailed to her and she
did not respond.
* * * * * * *
The Services’ policy with regard to filing a lien is to
file the lien in the county of residence, using the
last known address of record. The ownership of the
subject property does not dictate a lien filing. The
assessments were made in accordance with established
procedures for billing and demand per IRC 6321.
Collection or payment alternatives were discussed with
the taxpayer. Two potential alternatives are an in-
stallment agreement and an offer in compromise. These
cannot be considered until the taxpayer is in full
compliance with all filing requirements and submits
detailed financial information. Neither compliance or
financial information were provided to the Settlement
Officer during this Appeal Process. The taxpayer was
advised interest and penalty will continue to accrue
until the subject liabilities are paid in full or
settled in some other manner.
VERIFICATION OF LEGAL AND PROCEDURAL REQUIREMENTS
Prior to the lien being filed, the tax assessments were
made in accordance with established procedures. Notice
and demand made and no payment remitted. A notifica-
tion dated 4/7/2001 was sent to the taxpayers’ address
informing her of the potential for lien filing. No
response or payment in full resulted in the filing of a
Federal Tax Lien.
Sources of collection were identified prior to issuance
of the Notice of Intent to Levy. The under-lying
assessments were made in accordance with established
procedures.
RECOMMENDATION
ALL administrative procedures were followed by the
Service Center prior to issuance of the Notice of Lien
and the Notice of Intent to Levy. Both actions are
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011