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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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Last modified: May 25, 2011