- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011