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Summary of Determination
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 Internal Revenue Code (IRC)
section 6320.
• Your request for a Collection Due Process
(CDP) hearing was timely filed; accordingly,
you were entitled to a CDP Hearing for the
filing of the lien,
• We have held a Collection Due Process (CDP)
hearing by phone with the Appeals officer,
Kathryn A. Lester, your Power of Attorney,
John Turner and you, Deborah C. Goodin,
• You stated that the liability was
“Mathmaticaly incorrect,” that your wages and
other income are not “gross income” and are
not subject to tax,
• The service has issued a statutory notice of
deficiency to you on 2/11/2002, which de-
faulted since you did not petition the court
by 5/12/2002,
• You cannot dispute the liability under col-
lection due process since you have previously
been given the opportunity to dispute the
liability,
• The tax assessments were made on 7/8/2002,
• You have not raised any collection alterna-
tives,
• Therefore, the proposed lien action balances
the efficient collection of taxes with the
taxpayer’s legitimate concern that the col-
lection action be no more intrusive than
necessary.
The Appeals Office sustains the filing of the lien.
The case will be returned to the Compliance Office for
appropriate collection actions. [Reproduced liter-
ally.]
Petitioner filed a petition with the Court with respect to
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Last modified: May 25, 2011