- 5 - 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 frivolous. 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011