Neal Swanson - Page 6

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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