- 5 - Petitioner did not submit financial information on a Form 433-A, stating: “With regard to Appeals considering collection alternatives, this will not be necessary. I elect to make payment in full if a determination which is based upon requirements of law and administrative procedure shows that an amount is due and owed”. On May 13, 2003, petitioner attended a scheduled face-to- face meeting with the settlement officer. At the hearing, petitioner requested that she be permitted to audio record her hearing. Her request was denied. On July 9, 2003, respondent issued to petitioner a Notice of Determination Concerning Collection Action(s) under Section 6320 and/or 6330 (notice of determination). In the notice of determination, the settlement officer determined that it was appropriate for respondent to proceed with the proposed levy to collect petitioner’s tax liability. In regard to issues discussed at the hearing, the settlement officer wrote: You stated, at the hearing, that you know of no section of the Internal Revenue Code, which requires you to pay the tax. You also state that, despite admitted gross income in 1996 no authority is authorized to assess you. A discussion of Internal Revenue Code Sections 1, 61 and 63 took place at the hearing. * * * * * * * * * * No valid issues were raised. Throughout this proceeding you disputed the legal basis and procedures relating to the 1996 obligation. You have not taken a significant or positive step to resolve the 1996 delinquency. Your issues are without foundation. NoPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011