- 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