Kenneth A. Sapp - Page 5

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                    Year                     Date                                      

                    1990                  September 21, 1992                           
                    1991                  July 19, 1993                                
                    1992                  August 1, 1994                               
                    1993                  August 1, 1994                               
                    1996                  November 9, 1998                             
               The obligations remain unpaid; the transcripts indicate                 
               that assessments were made on the date the notices were                 
               issued.                                                                 
                    *       *       *       *       *       *       *                  
               This Appeals Officer has had no prior involvement with                  
               respect to these liabilities * * *.                                     
               The outstanding liabilities for 1990-1993 are based on                  
               returns you filed for those years.  The 1996 liability                  
               is based on a NOTICE OF DEFICIENCY. * * * Review of                     
               your file shows the Internal Revenue Service issued the                 
               NOTICE OF DEFICIENCY on June 5, 1998 for the 1996                       
               taxable year and you did not appeal the notice.                         
               Validity of the Assessment                                              
               The assessments are all valid according to the Appeals                  
               Officer’s review of the transcripts of account.                         
                    *       *       *       *       *       *       *                  
               Balancing Efficient Collection and Intrusiveness                        
               IRC Sec. 6330 requires that the Appeals Officer con-                    
               sider whether any collection action balance [sic] the                   
               need for efficient tax collection with the legitimate                   
               concern that any collection action be no more intrusive                 
               than necessary.  You have not provided an acceptable                    
               payment alternative to the proposed levy action that                    
               would satisfy the underpayments.  Therefore, it is                      
               determined that the proposed levy action balances the                   
               Government’s need for effective tax collection with                     
               your legitimate concerns of intrusiveness.                              








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