- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011