- 8 - 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 thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011