Isaiah Israel - Page 9

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          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 to                     





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