- 3 -
Revenue Officer Boyd Chivers, the individual identified as the
“Person to Contact” on the final notice of intent to levy, for
the purpose of requesting a 30-day extension of time to file a
request for an Appeals Office hearing. Federal Government
offices were closed on November 10, 2000, in observance of the
Veterans Day holiday. Consequently, petitioner left a voice mail
message for Revenue Officer Chivers requesting a 30-day
extension. On November 13, 2000, Revenue Officer Chivers called
petitioner and informed him that he would be granted a 30-day
extension of time to respond to the final notice of intent to
levy.
On or about December 14, 2000, respondent’s Appeals Office
received from petitioner a Form 12153, Request For A Collection
Due Process Hearing. Petitioner’s request was dated December 12,
2000. The Appeals Office initially informed petitioner that he
would be afforded a “collection due process” hearing under
section 6330. However, the Appeals Office subsequently concluded
that petitioner had failed to file his request for a hearing
within the time prescribed in section 6330, and, therefore, the
Appeals Office granted petitioner an “equivalent hearing”. See
sec. 301.6330-1(i), Proced. & Admin. Regs.
On August 8, 2001, the Appeals Office issued a “decision
letter” to petitioner stating that respondent would proceed with
collection by levy. Respondent’s decision letter stated in
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011