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In her notice of determination sustaining the proposed
collection action for 1996, Appeals Officer Sansbury stated, in
pertinent part, as follows:
For tax year ending 12/31/96, I reviewed IDRS
transcripts and reviewed the taxpayer’s
original return and determined Mr. Banis owes
the tax due. I explained to Mr. Banis the
closing letter he received from the Internal
Revenue Service for * * * [1996] was in
response to him providing documentation that
the income reported was incorrect. However,
the tax that is due for * * * [1996] is
correct.
OPINION
I. Introduction
If any person liable for Federal tax liability neglects or
refuses to make payment within 10 days of notice and demand, the
Secretary is authorized to collect the tax by levy on that
person’s property. Sec. 6331(a). As a general rule, at least 30
days before taking such action, the Secretary must provide the
person with a written final notice of intent to levy that
describes, among other things, the administrative appeals
available to the person. Sec. 6331(d). Upon request, the person
is entitled to an administrative review hearing before
respondent’s Appeals Office (Appeals Office hearing). Sec.
6330(b)(1). If dissatisfied with the Appeals Office
determination, the person may seek judicial review in the Tax
Court or a Federal District Court, as appropriate. Sec.
6330(d)(1).
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Last modified: May 25, 2011