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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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Last modified: May 25, 2011