- 2 - discretion in proceeding with a proposed levy on petitioner’s assets. Background At the time of the filing of the petition in this case, petitioner resided in Washington, D.C. At all relevant times, petitioner had outstanding income tax liabilities for taxable years 1990, 1991, 1992, 1993, 1995, 1999, and 2000 (collectively, petitioner’s unpaid tax liability). On July 20, 2002, respondent sent petitioner a Final Notice - Notice of Intent to Levy and Notice of your Right to a Hearing (levy notice) with respect to petitioner’s unpaid tax liability. In response, on August 15, 2002, petitioner timely filed a Request for a Collection Due Process Hearing (request) for taxable years 1990, 1991, 1992, 1993, 1995, 1999, and 2000. The request consisted, in its entirety, of the following: I do not understand the Account Summary page total please explain to me what is going on [sic] Assessed Balance, Statutory Additions, Total, how did you come up with that balance. [sic] I would like to make monthly payment that I can aford. [sic] I do realize that it may take me the rest of my life to pay. How do I start paying and were. [sic] Please contact me by mail or phone * * * HELP Between September 18, 2003, and July 13, 2004, petitioner and respondent’s Appeals officer engaged in telephonic conversations and exchanged correspondence. Petitioner and the Appeals officer discussed collection alternatives, including anPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011