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On February 7, 2002, respondent issued a Final Notice,
Notice of Intent to Levy and Notice of Your Right to a Hearing
(Notice of Intent to Levy), with respect to petitioners' taxable
year 1995. On February 27, 2002, in response to the Notice of
Intent to Levy, respondent received petitioners' Form 12153,
Request for a Collection Due Process Hearing (hearing).
E. Petitioners' Section 6330 Hearing
Appeals Officer Wendy Clinger (Ms. Clinger) was assigned to
handle petitioners' hearing. Petitioners met with her for their
hearing on November 21, 2002.
During the hearing, petitioners disputed their underlying
tax liability. Ms. Clinger advised them that they had already
had an opportunity to challenge the liability when they had a
trial before the Tax Court and could not do so again in the
hearing. Ms. Clinger explained that petitioners could discuss
the collection alternatives available to petitioners to satisfy
their tax liability.
At the hearing, petitioners submitted an OIC offering $1,000
to satisfy their outstanding 1995 tax liability which totaled
over $49,000, including accumulated interest. The $1,000 would
be paid within 90 days of written acceptance of their OIC.
Petitioners requested that their OIC be accepted in the interests
of effective tax administration, or doubt as to collectibility.
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