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On April 19, 2002, Appeals Officer Henry signed a memorandum
in which she recommended that the Notice of Intent to Levy should
not be withdrawn. The memorandum was approved by the Appeals
Office team manager on August 21, 2002. The attachment to the
Appeals Office memorandum concluded that the levy was no more
intrusive than necessary, the taxpayer’s offer was not adequate,
and:
There is no evidence to indicate that the taxpayer
would voluntarily pay the liability if the Notice of
Intent to Levy were removed. The proposed levy action
balances the need for efficient collection of taxes
with the taxpayer’s legitimate concern that any
collection action be no more intrusive than necessary.
On August 28, 2002, Appeals Officer Henry notified petitioner
that the Appeals Office had issued a determination letter. She
enclosed another Form 656 package to be completed and sent to
“the appropriate office for your area.”
Discussion
Neither the amount of petitioner’s liability nor the
procedural facts in this case are in dispute. Petitioner
contends that there was an abuse of discretion because he was not
provided information on how to appeal Appeals Officer Henry’s
determination that the levy proposed in March 2001 would not be
withdrawn and because the Appeals officer relied on erroneous
calculations by the revenue officer with respect to petitioner’s
monthly income.
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Last modified: May 25, 2011