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Notice of Levy/Seizure
1. The tax payer [sic], Mr. Joseph Dostal,
files this Collection Due Process Hearing
based on the grounds that he anticipates
an Offer in Compromise disputing the
collectability of the herein mentioned
tax but does not dispute the amount of
liability;
2. Tax Payer [sic] is currently experiencing
financial hardship and a levy it is felt
would constitute a substantial hardship
for tax payer [sic] and his family;
3. Upon further examination, taxpayer should
be placed in “non-collectability status”
during the pendency of this appeal.
As contemplated in his request for hearing, petitioner
submitted an offer-in-compromise approximately 4 months
later on August 20, 2003. Petitioner offered to pay
$20,000 to compromise the tax liabilities, plus any
interest, penalties, additions to tax, and additional
amounts required by law with respect to his individual
income tax for tax years “2000, 2001 & 2002”. As the
reason for submitting the offer-in-compromise, petitioner
checked the box entitled “Effective Tax Administration”,
which states as follows:
“I owe this amount and have sufficient assets to
pay the full amount, but due to my exceptional
circumstances, requiring full payment would cause
an economic hardship or would be unfair and
inequitable.” You must include a complete
Collection Information Statement, Form 433-A
and/or Form 433-B and complete Item 9.
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Last modified: May 25, 2011