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6201.
* * * * * * *
Relevant issues presented by the taxpayer
You have raised no specific issues other than frivolous
and groundless arguments.
On June 8, 2004 a telephone conference was held with
your Representative, Yourself and the Settlement Office
in attendance. At that conference your representative
continued to raise frivolous arguments and was advised
that those arguments would not be considered within the
context of the Collection Due Process Hearing.
In addition, in accordance with IRC Section 6330(2)(B),
you are prohibited from disputing the underlying
liability within the context of a Collection Due
Process Hearing because you had a prior opportunity to
do so, which you did not avail yourself of. Upon the
completion of your audit a Statutory Notice of
Deficiency was issued which remained unanswered.
At the same conference you stated that you would like
to file an amended income tax return and was advised to
file such return through the Philadelphia Service
Center or through the Office of Appeals. A date of
June 22, 2004 was established to submit the return.
As of the date of this letter you have not submitted
any information to assist in resolving your account.
* * * * * * *
Does the proposed collection action balance the need
for the efficient collection of taxes with the
taxpayer’s legitimate concern that the collection
action be no more intrusive than necessary?
The proposed Lien action balanced the need for the
efficient collection of taxes and is no more intrusive
than necessary.
Based on a review of the case activity records and case
transcripts the proposed lien action was necessary in
order to protect the government’s interest. Notice and
demand was given and the liability remained unpaid.
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Last modified: May 25, 2011