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regarding petitioner’s unpaid liabilities for 1993, 1994, and
1995. The notice states:
Summary of Determination:
It is determined that a levy is appropriate in your
case. Appeals has considered the information presented
at the Collection Due Process hearing. It is
determined that the collection of your unpaid accounts
by levy enforcement balances the government’s need to
efficiently collect your 1993, 1994 and 1995 tax
liabilities with your concerns of intrusiveness.
* * * * * * *
Legal and Procedural Requirements:
It has been concluded that all required laws and
procedures have been followed. The only legal
requirements before taking general enforcement action
are the notice and demand and the notice of intent to
levy with a notice of right to a Collection Due Process
Hearing.
Internal computer records indicate that notice and
demand of payment have been made within the required
time periods for the 1993, 1994 and 1995 years at
issue.
The notice of intent to levy, Letter 1058, was properly
mailed and included with this notice were all required
enclosures. These enclosures include the Form 12153,
which you used to make your Collection Due Process
hearing request.
Issues Raised by the Taxpayer:
In your hearing request you challenged the assessment
of the tax liabilities. You previously challenged the
assessment in the United States Tax Court. The Court
issued its “Order of Dismissal and Decision” dated
February 3, 1998. The Court’s decision is final.
Appeals will not consider challenges to the underlying
liability because you previously challenged the
liability and the Tax Court has issued its decision
that the taxes are due and owing.
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Last modified: May 25, 2011