- 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 suggested. 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 appropriate. 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