- 7 - 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Appeals Officer Henry signed a memorandum in which she recommended that the Notice of Intent to Levy should not be withdrawn.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information on how to appeal Appeals Officer Henry’s determination that the levy proposed in March 2001 would not be withdrawn and because the Appeals officer relied on erroneous calculations by the revenue officer with respect to petitioner’s monthly income.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011