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returned the waiver necessary to continue your
case with the audit reconsideration unit.
An attachment to the notice of determination states as
follows:
Applicable Law and Administrative Procedures
* * * * * * *
This Appeals Officer has had no prior involvement with
this taxpayer with respect to these appealed
assessments.
Validity of the Assessment
The assessment is valid.
Challenges to the Existence or Amount of the Liability
Taxpayer wanted to [sic] what is the definition of
income. The Appeals Officer mailed the taxpayer the
first 6 pages of the “THE TRUST ABOUT FRIVLLOUS [SIC]
TAX ARGUMENTS” CHAPTER #1.
SPOUSAL DEFENSES
Not applicable.
Collection Alternative Considered
Taxpayer stated he wanted an Installment Agreement,
[sic] However since the taxpayer is not in compliance.
[sic]
Balancing Efficient Collection Intrusiveness
IRC�6330 requires that the Appeals Officer consider
whether any collection action balance the need for
efficient tax collection with the legitimate concern
that any collection action be no more intrusive than
necessary. The levy action is appropriate.
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Last modified: May 25, 2011