- 6 - intrusive than necessary. An attachment to the notice of determination stated in pertinent part: I. Applicable Law and Administrative Procedures. On June 28, 2001, the Internal Revenue Service mailed a Letter 11, FINAL NOTICE - NOTICE OF INTENT TO LEVY AND NOTICE OF YOUR RIGHT TO A HEARING, concerning unpaid Form 1040 for the periods [sic] ending December 31, 1997. In response to our letter you submitted Form 12153, received on July 17, 2001 requesting a Collec- tion Due Process Hearing. * * * * * * * * * * Review of transcripts have confirmed the tax was assessed, and notice and demand was mailed to the taxpayer at his last known address, and there is still a balance due. * * * * * * * * * * The record shows that such a notice was mailed to you via certified mail, return receipt re- quested, on June 28, 2001. * * * * * * * * * * The Appeals Officer assigned to hear your case has had no prior involvement with respect to any of your tax liabilities. * * * * * * * * * * You filed a timely protest and were provided ample time and opportunity to schedule a face-to-face, telephonic or correspondence hearing with the Appeals officer, and to raise any relevant issues at such a hearing. You declined to schedule a hearing, notwith- standing the fact that a letter was sent to you on October 16, 2001 at the address shown on your hearing request and a second letter was sent to you on March 14, 2002 at the address shown on IRS records, confirmed by you by phone on March 14, 2002. Other calls werePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011