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Applicable Law and Administrative Procedures
IRC section 6631(d) requires that the IRS notify a
taxpayer at least 30 days before the day of levy.
Notice CP 523 was mailed to you via certified mail.
IRC section 6630(a) states that no levy may be made
unless the IRS notifies a taxpayer of the opportunity
for a hearing with the IRS Office of Appeals. Notice
CP 523 “Notice of Intent to Levy” was mailed to you via
certified mail. You made a timely request for a hear-
ing.
IRC section 6330(c) allows you to raise any relevant
issue relating to the unpaid tax or the proposed levy
at the hearing.
Relevant Issues Raised by the Taxpayer
You did not attend the Scheduled hearing and have not
responded to any contact by the Appeals Office.
Balancing Collection and Intrusiveness
The outstanding tax liabilities for 1990, 1991, 1992
and 1993 are based on the returns you filed for those
years. The 1996 liability is based on information the
IRS had on file. * * *
Since you have not responded to any contact by the
Appeals Office, your case will be returned to the
Collection function for appropriate action.
Respondent acknowledges in respondent’s response to peti-
tioner’s motion: “The February 5, 2002, Notice of Determination
did not contain all the statements required by Treas. Reg. �
301.6330-1(e)(3) Q&A-E8. For this reason, Appeals sent to
petitioner the Supplemental Notice dated May 1, 2003.”
The “Supplemental Notice dated May 1, 2003" referred to in
respondent’s response to petitioner’s motion is a supplemental
notice of determination concerning collection actions(s) under
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Last modified: May 25, 2011