Mary K. Dues - Page 5

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          tax lien) with respect to taxable years 1997 and 1998.                      
               In early June 2001, in response to the notice of intent to             
          levy and the notice of tax lien, petitioner, through her autho-             
          rized representative, mailed to respondent Form 12153, Request              
          for a Collection Due Process Hearing (Form 12153), and requested            
          a hearing with respondent’s Appeals Office (Appeals Office).  In            
          her Form 12153, petitioner raised various challenges to respon-             
          dent’s collection activity that respondent determined to be                 
               A settlement officer with respondent’s Appeals Office                  
          (settlement officer) scheduled several hearings (Appeals Office             
          hearings) with petitioner and her authorized representative with            
          respect to the notice of intent to levy and the notice of tax               
          lien.  Petitioner and her authorized representative refused to              
          attend any of the Appeals Office hearings that the settlement               
          officer had scheduled.  That was because the settlement officer             
          refused to allow petitioner and her authorized representative to            
          audio record any such hearing.                                              
               On February 14, 2003, the Appeals Office issued to peti-               
          tioner a notice of determination concerning collection action(s)            
          under section 6320 and/or 6330 (notice of determination).  That             
          notice stated in pertinent part:                                            
               It has been determined that the lien filing and pro-                   
               posed levy action are sustained.  The Internal Revenue                 
               Service has complied with code and procedural require-                 
               ments in collecting the tax.                                           

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