- 11 - discuss the law and how it applies to the facts in your case. The primary purpose of this hearing is to verify all legal and procedural requirements were followed in proposing the collection action for the periods listed above. Additionally, the consideration of less intrusive collection alternatives will be a focus of this hearing. Please be prepared to discuss any alternative that you wish for me to consider in an effort to resolve your case. In addition, Luhmann advised petitioners that they were not entitled to a hearing on the filing of a Federal tax lien because no such lien had been filed. By letter dated October 2, 2002, petitioners elected to hold a telephonic hearing, which was subsequently held on October 21, 2002, between Luhmann and McKinnon. On October 25, 2002, respondent filed a Notice of Federal Tax Lien against petitioners for their unpaid income tax liabilities for 1999 and 2000 in the public records of Lee County, Florida. Petitioners were notified of the filing of the Federal tax lien as required under section 6320, but they did not request that a hearing be held with respect to the filing of that lien. On October 30, 2002, Luhmann issued a notice of determination to each petitioner in which he sustained the proposed levy to collect petitioners’ unpaid income tax liabilities for 1999 and 2000. Luhmann also issued a separate notice of determination to Clawson in which he sustained the proposed levy to collect the unpaid portion of the trust fundPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011