- 7 - Based on these results, Appeals Officer Otterson was unable to accept petitioner’s second OIC because petitioner could pay his full tax liability within the period of limitations for collection. Appeals Officer Otterson advised petitioner that respondent would be able to accept an installment agreement that would pay off petitioner’s tax liability and to contact him during the week of May 14, 2001, if petitioner were interested in discussing this possibility. Petitioner never contacted Appeals Officer Otterson regarding an installment agreement. On July 25, 2001, respondent issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 to petitioner regarding his 1989, 1990, 1991, 1992, 1993, and 1994 tax years (notice of determination). In the notice of determination, respondent determined that the Federal tax lien should remain in place. The notice of determination further explained: The taxpayer prepared an offer in compromise form which was analyzed by Appeals * * * . It was determined that the full liability could be collected within the collection statute. The taxpayer was given the opportunity to use an installment agreement but he did not respond. * * * The taxpayer has not responded to the only available voluntary payment option. This was the installment agreement. The Notice of Federal Tax Lien should remain in place. On August 20, 2001, petitioner timely filed an imperfect petition for lien or levy action under Code section 6320(c) or 6330(d) seeking review of respondent’s determination to proceed with collection of petitioner’s 1989, 1990, 1991, 1992, 1993, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011