Carolyn D. Ramirez - Page 5

                                        - 4 -                                         
          that she still wanted to propose an offer in compromise.  The               
          Appeals officer asked petitioner to submit a completed                      
          Form 433-A.                                                                 
               On August 5, 2002, the Appeals officer still had not                   
          received a Form 433-A from petitioner and had not heard from her            
          since July 11, 2002.  On August 5, 2002, the Appeals officer                
          administratively closed petitioner’s case for a determination               
          based upon the information in her file.  On August 8, 2002, the             
          Appeals officer received a package from petitioner containing a             
          completed Form 433-A and related financial documents (the offer             
          in compromise materials).  The Appeals officer considered the               
          offer in compromise materials to be late, and he did not review             
          the information.  On August 12, 2002, the Appeals officer issued            
          a Notice of Determination.  The Notice of Determination stated              
          that petitioner did not have an offer in compromise pending at              
          this time and set forth the following rationale for preceding               
          with the levy:                                                              
               Although a levy is intrusive, since the information                    
               related to the taxpayer’s financial specifics were not                 
               provided so that we might evaluate the collection                      
               alternative, the proposed collection action balances                   
               the need for the efficient collection of the taxes with                
               the legitimate concern of the taxpayer that any                        
               collection action be no more intrusive than necessary.                 











Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011