Nicholas & Carrie Cozzens - Page 8

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               The issues discussed below are those presented Form                    
               12153, Request for a Collection Due Process Hearing.                   
               Issue number one                                                       
               The taxpayers did not agree with the filed Notice of                   
               Federal Tax Lien.  Their stated reason:                                
               .... the IRS has not complied with applicable laws and                 
               administrative procedures, the collection procedures                   
               are inappropriate and illegal, and Mr. and Mrs. Cozzens                
               have no liability for the taxes and penalties at issue.                
               My Comments                                                            
               Notice and Demand was [sic] made on 04/24/2000 for both                
               balance due periods at issue.  The taxes remained                      
               unpaid; subsequently, a Notice of Federal Tax Lien was                 
               recorded on 02/07/2002 and the taxpayers notified of                   
               their right to a hearing.                                              
               Administrative procedures were followed and the tax                    
               liabilities remain unpaid.                                             
               Furthermore, IRC � 6323(j) gives the Internal Revenue                  
               the authority to withdraw a Notice of Federal Tax Lien                 
               under * * * [certain] circumstances * * *                              
                  *       *       *       *       *       *       *                   
               The taxpayers do not meet any of the criteria described                
               in IRC � 6323(j), nor did they offer any relevant                      
               reason why the lien should be withdrawn.                               
               There were no other issues raised by the taxpayer.                     
                    3.  Has the need for efficient tax collection been                
                    balanced with taxpayer’s concern that the                         
                    proposed collection action be no more                             
                   intrusive than necessary?                                          
               IRC � 6330 requires that the Office of Appeals consider                
               whether any collection action balances the need for                    
               efficient collection of taxes with the taxpayers’                      
               legitimate concern that any collection be no more                      
               intrusive than necessary.                                              
               Our determination is to deny relief, and sustain the                   

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