John A. Roberts - Page 8

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               sufficient to overcome the presumption of correctness                  
               in regard to the existing signed Form 900.                             
               On March 5, 2002, respondent mailed to petitioner a Notice             
          of Determination Concerning Collection Action(s) under Section              
          6320 and/or 6330 (the notice of determination) determining that             
          the tax assessments made against petitioner were valid and                  
          appropriate, all requirements of various applicable law and                 
          administrative procedures were followed, and issuance of the                
          notice of levy was appropriate given the facts and circumstances            
          presented by petitioner.  In an attachment to the notice of                 
          determination (“Attachment - 3193"), respondent rejected                    
          petitioner’s claim that the extensions signed by him were                   
          invalid:                                                                    
               Issue Raised by You                                                    
               You state that you dispute the validity of the                         
               collection statute extension.  It was determined by our                
               office that there is no evidence to support your claim                 
               that the extension to extend the collection statute of                 
               limitations is invalid.                                                
                                     Discussion                                       
          I.  Introduction                                                            
               If any person liable for Federal tax liability neglects or             
          refuses to make payment within 10 days of notice and demand, the            
          Secretary is authorized to collect the tax by levy on that                  
          person’s property.  Sec. 6331(a).  As a general rule, at least 30           
          days before taking such action, the Secretary must provide the              
          person with a written final notice of intent to levy that                   





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