Jerry B. and Donna E. Clawson - Page 11

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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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