Lance A. McLee - Page 7

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               also made, and messages left to which you did not                      
               respond. 1996, 1999, 2000 and 2001 have still not been                 
               filed.                                                                 
               This Appeal Officer has had no prior involvement with                  
               respect to these liabilities.  Our determination in                    
               this matter is based on the information available to us                
               in the administrative file.                                            
               We find that all legal and procedural requirements for                 
               the proposed levy have been satisfied.                                 
               II. Relevant Issues Presented by the Taxpayer.                         
               Challenges to the Existence or Amount of the Liability.                
               Your request states “I believe it to be a big mistake.                 
               Need time to obtain documents.”  This was July 11,                     
               2001, you should have had time to get those documents                  
               by now.  You stated on March 14, 2002 by phone that JK                 
               Harris would be handling your Appeal.  I requested by                  
               phone and letter to have form 2848 to me within 10                     
               days, and delinquent returns and other financial infor-                
               mation to me by April 25, 2002.  No documents or power                 
               of attorney forms have been provided to date.                          
               No other issues were raised by the taxpayer.                           
               Challenges to the Appropriateness of the Proposed                      
               Collection Action.  You were given the opportunity to                  
               raise any relevant issue relating to the unpaid tax or                 
               the proposed levy in accordance with IRC Section                       
               6330(c).  However, you did not respond to the confer-                  
               ence letter mailed to you, or the phone messages left                  
               for you.  You did not contact the Appeals Officer to                   
               schedule either a face-to-face hearing or a telephonic                 
               hearing.                                                               
               III. Balancing Efficient Collection and Intrusiveness.                 
               Although a levy is intrusive, since you presented no                   
               information or any alternatives for collection, the                    
               levy is the most efficient method of collection remain-                
               ing.  The proposed levy therefore balances the need for                
               efficient collection with the taxpayer’s legitimate                    
               concern that the collection action be no more intrusive                
               than necessary.                                                        







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