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for a hearing. Respondent’s Appeals officer determined that the
offer in compromise should not be accepted because the offer and
supporting financial information were incomplete. Petitioner did
not comply with the Appeals officer’s request to provide the
complete information. On January 17, 2002, a hearing was held
between respondent’s Appeals officer and petitioner’s counsel
Judy E. Hamilton. In connection with the hearing, the Appeals
officer reviewed Internal Revenue Service transcripts of account
for petitioner’s 1989 tax liability.
On April 12, 2002, respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) under Section 6320
and/or 6330 (Notice of Determination) regarding petitioner’s 1989
Federal income tax liability. On May 13, 2002, petitioner filed
with the Court a Petition for Lien or Levy Action. Neither in
the petition nor in the previous request for a hearing did
petitioner raise any issues with respect to the existence or the
amount of the underlying tax liability. Instead, petitioner
alleges that he was denied his right to a hearing under section
6330, that he was denied participation in the proceedings
relating to offer in compromise, and that he was subjected to
punitive conduct by personnel of the Internal Revenue Service
(IRS). In addition, petitioner maintains that the factual
foundation of the Notice of Determination lacked veracity.
Petitioner asks the Court to remand this case to Appeals for
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Last modified: May 25, 2011