William G. Wells - Page 3

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            respondent a Form 12153, Request for a Collection Due Process                               
            Hearing, regarding his 1991 and 1992 tax years (hearing request).                           
            In explaining his disagreement with the proposed levy, petitioner                           
            wrote “SEE ATTACHED LETTER”.  Petitioner attached to his hearing                            
            request a 2-page letter from his representative, Steven Toscher.                            
            The attached letter stated:                                                                 
                  As you are aware, Mr. Wells has not been able to                                      
                  continue the installment obligation entered into in                                   
                  July of 1998.  The installment obligation was premised                                
                  on Mr. Wells receiving $24,969 in rental income from                                  
                  Miramar Hotel leases.  Unfortunately, as you are also                                 
                  aware, Mr. Wells is involved in litigation with Fujita                                
                  USA which has caused the lessee to terminate the rental                               
                  payments.  Thus, Mr. Wells has no ability to continue                                 
                  to make said payments.  Mr. Wells requests that IRS                                   
                  modify the agreement based upon his current ability to                                
                  pay.  A modification of an installment obligation will                                
                  facilitate collection of such liabilities.                                            
                  Enclosed please find IRS Form 12153 where Mr. Wells                                   
                  requests a due process hearing pursuant to I.R.C.                                     
                  �6330(b) with respect to the IRS Notice of Intent to                                  
                  Levy.  As stated above, a modified installment                                        
                  agreement or an Offer in Compromise are more                                          
                  appropriate collection alternatives given Mr. Wells’                                  
                  financial situation.  Mr. Wells continues to explore                                  
                  any and all alternatives in satisfying the IRS’                                       
                  previous assessments.  It will not be productive for                                  
                  the IRS or Mr. Wells to levy on any of his “assets.”                                  
                  Please have the Appeals Officer assigned to this case                                 
                  call me to arrange a mutually convenient time to meet                                 
                  and discuss this matter.                                                              
                  On July 6, 2000, Appeals Officer Richard William Bailey and                           
            Mr. Toscher met to hold a section 6330 hearing (July 6, 2000,                               









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