Deborah Carman Goodin - Page 6

                                        - 6 -                                         
               payment, at his last known address, as provided for in                 
               IRC � 6303.  Review of transcripts have confirmed the                  
               tax was assessed 7/8/2002, and notice and demand was                   
               mailed to the taxpayer at his last known address, and                  
               there is still a balance due.                                          
               IRC section 6320(a) provides that the IRS will notify a                
               taxpayer of the filing of a NFTL and of the right to a                 
               hearing before the IRS Office of Appeals with respect                  
               to the filing of NFTL.  Such notification was mailed to                
               you 3/24/2003.                                                         
                  *       *       *       *       *       *       *                   
               This Appeals Officer has had no prior involvement with                 
               respect to these liabilities.                                          
                      Relevant Issues Presented by the Taxpayer                       
               The request for a Collection Process Due Hearing filed                 
               by the taxpayer stated “mathmaticaly incorrect.”  The                  
               taxpayer did not file a return, and does not believe                   
               that she has “gross income” or owes the tax.  A proper                 
               assessment was made on 07/08/2002 after mailing the                    
               Statutory Notice of Deficiency to the taxpayer’s last                  
               know address on 2/11/2002.  She has been given the                     
               opportunity to dispute the assessment before it was                    
               made.  No alternative to the filing of the NFTL was                    
                 Balancing the Efficient Tax Collection with Concern                  
                               Regarding Intrusiveness                                
               Appeals has verified, or received verification, that                   
               applicable laws and administrative procedures have been                
               met; has considered the issues raised, and has balanced                
               the proposed collection action with the legitimate                     
               concerns that such action be no more intrusive than                    
               necessary as required by IRC 6330(c)(3).  The case will                
               be returned to compliance for any action they deem                     
               The filing of the lien, in this case, properly balances                
               the need for efficient collection action with concerns                 
               over the level of intrusiveness necessary to accomplish                
               collection of the liability.  It is Appeals determina-                 
               tion that Compliance properly followed all procedures                  
               and properly filed the lien.                                           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011