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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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