Randy S. Quigley - Page 7

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               relevant to paying your tax liability.  These include,                  
               for example, offering other ways to pay the taxes you                   
               owe, such as an installment agreement or offer in                       
               compromise.  The Internal Revenue Manual determines                     
               whether Appeals can accept your proposal.  If you wish                  
               to have a face-to-face conference, please write me                      
               within 15 days from the date of this letter or February                 
               23, 2004 and describe the legitimate issues you will                    
               discuss.                                                                
          Petitioner did not respond to the Appeals officer’s February 6,              
          2004 letter.                                                                 
               On April 8, 2004, the Appeals Office issued to petitioner a             
          notice of determination concerning collection action(s) under                
          section 6320 and/or 6330 (notice of determination).  The notice              
          of determination stated in pertinent part:                                   
               Summary of Determination                                                
                    •    A review of the administrative file                           
                         indicated that all statutory and admin-                       
                         istrative requirements that needed to be                      
                         met with respect to the Notice of Intent                      
                         to Levy being issued were in fact met in                      
                         your case.                                                    
                    •    All relevant issues raised by you were                        
                         addressed.                                                    
                    •    You suggested no collection alterna-                          
                         tives.                                                        
                    •    IRC Sections 6320 and 6330 require that                       
                         the Appeals Officer consider whether any                      
                         collection action balance the need for                        
                         efficient tax collection with the legit-                      
                         imate concern that any collection action                      
                         be no more intrusive than necessary.                          
                         The proposed levy action appears appro-                       
                         priate in that your liabilities are                           
                         based on your non-compliance with the                         
                         tax laws and that you continue attempt-                       
                         ing to circumvent the tax system with                         
                         various time worn frivolous arguments.                        






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