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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 fund
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Last modified: May 25, 2011