- 9 - and advanced the same contentions and arguments that petitioner set forth in petitioner’s attachment to Form 12153. On November 28, 2001, the Appeals Office mailed to peti- tioner a notice of determination. An attachment to the notice of determination stated in pertinent part: Legal and Procedural Requirements: With the best information available, the requirements of various applicable law or administrative procedures have been met. IRC � 6321 provides a statutory lien when a taxpayer neglects or refuses to pay a tax liability after notice and demand. Computer records indicate the Service Center issued these notices; the obligation remains unpaid. IRC � 6331(d) requires that IRS must notify a taxpayer at least 30 days before a notice of levy may be issued. The revenue officer issued L-1058 [notices of intent to levy] for all periods considered at this hearing. * * * * * * * The taxpayer was given the opportunity to raise any relevant issue relating to the unpaid tax or the pro- posed levy at the hearing in accordance with IRC � 6330(c). This Appeals Officer has had no prior involvement with respect to these liabilities. Relevant issues presented by the taxpayer The issues you raised on Form 12153 dated May 10, 2001 [sic], are of a kind not considered in Appeals, nor contemplated by the due process provisions. * * * You filed Form 1040s on May 28, 1999, June 1, 1999 and May 28, 1999, for tax years 1994, 1995 and [1996], respec- tively, reflecting what you voluntarily determined to be your tax liability. The 1995 and 1996 returns were accepted as filed. You were advised to file another Form 1040 for 1994 to change your filing status toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011