- 7 -
amount of petitioner’s unpaid liability for 2000 at the Appeals
Office hearing or in the petition that she filed in this case.
On September 25, 2003, the Appeals Office issued a notice of
determination concerning collection action(s) under section 6320
and/or 6330 (notice of determination) to petitioner. An attach-
ment to that notice stated in pertinent part:
Summary & Recommendation
* * * * * * *
You have not put forth an appropriate alternative to
the Notice of Federal Tax Lien. Therefore, it is the
determination of Appeals that the lien should remain on
file until the balance due in question is fully paid.
Brief Background
You submitted an offer in compromise. The offer in
compromise was returned to you, because you did not
provide the information requested by the offer exam-
iner. The Notice of Federal Tax Lien was filed in
conjunction with the return of your offer. In response
to the lien filing, you filed Form 12153.
It was determined that you do not have the ability to
pursue any alternatives to the lien at this time.
Verification that Law and Procedure were Followed
Information in the administrative case file and related
computer records shows that the IRS followed law and
procedure in this case. The assessment in question is
based upon a return filed by you. IRS records show
that the assessment was properly made under IRC Section
6201. Notice and demand was sent to you as required
per IRC Section 6303. There was a balance due at the
time the Collection Due Process Notice was issued as
required by IRC sections 6322 and 6331(a). The IRS
gave you opportunities to pay the balance due volun-
tarily, but you failed to do so. The Compliance Divi-
sion recorded the Notice of Federal Tax Lien to protect
the Government’s interest.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011