Mary K. Dues - Page 6

                                        - 6 -                                         
          An attachment to the notice of determination stated in pertinent            
          part:                                                                       
                               DISCUSSION AND ANALYSIS                                
               WERE THE REQUIREMENTS OF ANY APPLICABLE LAW OR PROCE-                  
               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                  
                    hearing.                                                          
               •    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                  





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011