- 3 -
provide certain items of financial information prior to the
hearing in order for respondent’s Appeals Office to consider
alternative methods of collection. By letter dated December 22,
2003, respondent’s Dallas Appeals Office notified petitioners’
attorney that the section 6330 hearing was scheduled for January
14, 2004. By letter dated December 22, 2003, petitioners’
attorney notified respondent that he no longer represented
petitioners. On January 14, 2004, respondent’s Appeals Office
called petitioners directly to determine whether petitioners
still wanted the hearing held. Petitioners did not return the
call and did not show up for the hearing. Moreover, petitioners
did not submit any financial information to the hearing officer
and did not submit an offer in compromise.
On February 17, 2004, respondent issued to petitioners a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 sustaining the proposed collection
action as petitioners “did not respond to the letters issued
setting conferences” and “No agreement or viable option could be
discussed since they [petitioners] did not show up for the
hearings set or submit anything in writing either.”
OPINION
Section 6331(a) provides that, if any person liable to pay
any tax neglects or refuses to do so within 10 days after notice
and demand, the Secretary can collect such tax by levy upon
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011