- 5 -
Harris to represent him. On May 10, 2002, the Appeals officer
again telephoned petitioner (May 10, 2002 telephone call) but was
unable to reach him. The Appeals officer left petitioner another
message requesting petitioner to telephone him. Petitioner did
not respond to the April 11, 2002 telephone call or the May 10,
2002 telephone call.
On May 22, 2002, the Appeals Office mailed to petitioner a
notice of determination concerning collection action(s) under
[section] 63303 (notice of determination). The notice of deter-
mination stated in pertinent part:
Summary of Determination
! Your request for a Collection Due Process
(CDP) hearing was timely filed; accordingly,
you were entitled to a CDP Hearing,
! You failed to prosecute or pursue your re-
quest for a hearing,
! You stated in your request that you signed
July 11, 2001, that you need time to obtain
documents and information, you have had sub-
stantial time for this, but have not provided
anything,
! A viable collection alternative is not viable
as you have not responded and are not current
in filing delinquent returns,
! Since you have not responded, the proposed
levy action balances the efficient collection
of taxes with the taxpayer’s legitimate con-
cern that the collection action be no more
3All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011