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September 15, 1997, and in Benewah County on September 12, 1997.
The lien for the 1996 taxes was filed in Benewah County on
December 12, 1998.
On September 14, 1999, pursuant to section 6331, the IRS
mailed to petitioner a “Final Notice--Notice of Intent to Levy
and Notice of Your Right to a Hearing” for 1986 through 1996. In
a protest letter dated October 12, 1999, petitioner requested a
hearing under section 6330 to review the proposed levy. In a
letter dated December 1, 1999, Appeals Officer Lavada Harmon
(Harmon) informed petitioner that there was no record of an offer
in compromise’s having been submitted to the IRS, although
petitioner’s counsel had indicated that such an offer had been
made and rejected. Harmon enclosed the necessary forms to submit
an offer in compromise and requested that petitioner complete and
return the forms to her by December 20, 1999. A telephonic
hearing was held in December 1999 between Harmon and petitioner’s
counsel. Petitioner never provided the forms or financial
information necessary for consideration of an offer in
compromise.
The IRS Office of Appeals reviewed the proposed levy and
sent a notice of determination dated February 25, 2000, stating
that “Appeals should not restrict the appropriate collection
action.” The notice of determination explained:
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Last modified: May 25, 2011