Howard Dysle - Page 6

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          petitioner did not submit proof of missing payments for 1996 and            
          1998 or a completed Form 433-A to Mr. Wergin.                               
               In the notice of determination, respondent determined that             
          the notice of lien was appropriate, balanced the need for                   
          efficient collection with the legitimate concerns of the                    
          taxpayer, and was no more intrusive than necessary.  In an                  
          attachment to the notice of determination, Mr. Wergin stated:               
          (1) He considered only matters related to 1996 and 1998 as                  
          petitioner received a hearing notice only for those two years;              
          (2) he verified that all requirements of any applicable law or              
          administrative procedure had been met; (3) he reviewed                      
          petitioner’s underlying liability for 1996; (4) he reviewed                 
          whether payments were properly credited to petitioner’s account;            
          (5) he provided petitioner official transcripts of his 1996 and             
          1998 tax years; (6) he offered petitioner an installment                    
          agreement to pay the outstanding balance that petitioner                    
          declined; (7) he told petitioner he might be eligible for                   
          uncollectible status given petitioner’s statements about his                
          finances; (8) he provided petitioner a Form 433-A, but petitioner           
          did not return the Form 433-A; and (9) he gave petitioner                   
          additional time after the hearing to provide proof, including               
          canceled checks, but petitioner did not submit this information             
          to him.                                                                     








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