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On August 30, 2001, petitioner signed a Form 433-A,
Collection Information Statement for Individuals, and sent it to
respondent.
On September 6, 2001, petitioner submitted a Form 12153,
Request for a Collection Due Process Hearing, regarding her 1997
and 1999 tax years (hearing request). Petitioner stated that she
disagreed with respondent’s decision to levy because she was
unable to pay the assessments in full at that time. Petitioner,
however, did not dispute the amount of the liabilities. She
requested that respondent consider an installment payment plan in
lieu of enforced collection action.
On January 23, 2002, petitioner sent respondent spreadsheets
showing the sales she closed and commissions she earned during
2001 and two pages of claimed business expenses.
On the basis of all of the information provided by
petitioner, respondent prepared a monthly income and expense
analysis. Respondent concluded that petitioner had the ability
to pay $5,599 per month toward her outstanding 1997 and 1999 tax
liabilities.
On March 19, 2002, respondent assigned Appeals Officer
Denise Mountjoy to petitioner’s hearing request. Appeals Officer
Mountjoy reviewed the administrative file and obtained
transcripts of petitioner’s account for 1997 and 1999. The
administrative file and transcripts of account confirmed the
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Last modified: May 25, 2011