- 4 -
and/or 6330 on June 19, 2003 (notice of determination).
Respondent stated, in part:
For years 1996 and 1997, statutory notices of
deficiency were mailed to taxpayer at the appropriate
address. Accordingly, the underlying liability cannot
be considered under CDP proceedings for these years.
For tax years 1998, 2000, and 2001 the taxpayer did not
present evidence to substantiate her position that the
underlying liability was not appropriate as assessed.
The filing of the Notice of Federal Tax Lien is
appropriate. The liability is valid and outstanding.
With respect to the proposed levy action for 2000 and 2001,
respondent issued a separate notice of determination on June 19,
2003. Respondent sustained the proposed levy, stating in part:
Taxpayer did not present evidence to substantiate her
position that the underlying liability was not
appropriate as assessed. The liability is valid and
outstanding.
Taxpayer did not propose any collection alternatives.
Upon receiving the notices of determination, petitioner
filed a petition with this Court. In addition, petitioner
contacted respondent in an effort to arrange for a collection
alternative. On June 26, 2003, petitioner sent respondent a
package of documents purporting to be an offer in compromise
(OIC). Petitioner did not provide specific information regarding
her financial situation. She explained generally that she had
limited resources and no relatives to help her, that she had lost
her employment, that she lived very modestly, and that she
anticipated incurring significant medical and long-term care
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011