- 12 - In the attached memorandum, petitioner asserted he would complete his delinquent returns within 60-90 days to prove that he did not owe the tax liabilities determined by respondent. In the attached memorandum, petitioner also stated he was appealing Revenue Officer Angotta’s “levy warning letter” dated February 14, 2000, which, according to petitioner, stated: “Enforced collection may include placing a levy on your bank accounts, wages, receivables, commissions, etc.”6 In the attached memorandum, petitioner asserted: “Mr Angotta informed me over the telephone that I have until March 15, 2000 to appeal this action.” In the attached memorandum, petitioner also said Revenue Officer Angotta failed to respond to petitioner’s messages left on Revenue Officer Angotta’s answering machine before February 11, 2000, in which petitioner stated that he was ready to personally meet with Revenue Officer Angotta to hand in his appeal. In a letter dated June 22, 2000, Appeals Officer William A. Hirsch (Appeals Officer Hirsch) informed petitioner that respondent’s NFTL had been assigned to him for consideration. After repeated failed attempts by Appeals Officer Hirsch and petitioner to get in touch with each other, Appeals Officer Hirsch, in a letter dated July 26, 2000, informed petitioner that 6The Feb. 14, 2000, letter was not part of the record.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011