Mary K. Dues - Page 6

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          An attachment to the notice of determination stated in pertinent            
                               DISCUSSION AND ANALYSIS                                
               DURE MET?                                                              
               Based upon the best information available, the Service                 
               complied with the applicable laws and procedures in                    
               pursuing collection of the tax liabilities.                            
               •    The assessments were made per IRC �� 6201, 6203,                  
                    6211, 6212, and 6213.                                             
               •    The notice and demand for payment letter was                      
                    mailed to the last known address, within 60 days                  
                    of the assessment, as required by IRC � 6303.                     
               •    IRC � 6321 provides a statutory lien when a tax-                  
                    payer neglects or refuses to pay a tax liability                  
                    after notice and demand.  To be valid against                     
                    third parties, except for other government enti-                  
                    ties, a notice of lien must be filed in the proper                
                    place for filing per IRC �� 6323(a) and (f).                      
               •    IRC � 6320 requires the IRS to give notice to a                   
                    taxpayer in writing no later than five working                    
                    days after filing a notice of lien of the tax-                    
                    payer’s right to request a hearing.  This notice                  
                    was mailed to you.                                                
               •    IRC [�] 6330 requires the IRS to give notice to a                 
                    taxpayer in writing at least thirty days prior to                 
                    levy action of the taxpayer’s right to request a                  
               •    There was a balance due when the CDP notice was                   
                    issued per IRC � 6322.  The CDP notice was sent by                
                    certified mail return receipt requested to your                   
                    last known address.                                               
               •    The collection statute has been suspended as the                  
                    result of your CDP request.                                       
               The above information was verified through a review of                 
               computer transcripts and information contained in the                  

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Last modified: May 25, 2011