- 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