- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011