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I. Verification of Legal and Procedural Requirements
The required notice and demand was sent for each period
on the same date as the assessment.
* * * * * * *
With the best information available including computer
records and the administrative file it has been deter-
mined that all applicable legal and administrative
requirements have been met.
This settlement officer has had no known previous
dealings with this taxpayer for the tax liability for
the periods listed above.
* * * * * * *
II. Issues Raised by the Taxpayer
The taxpayer had an earlier opportunity to raise issues
concerning the underlying tax liability for the 1998
and 1999 tax liability. A Statutory Notice of Defi-
ciency (SND) was issued for these assessments. It is
known that the taxpayer received a copy of this notice
because he provided a copy of it with his appeal re-
quest. The tax liability on earlier periods [including
1994 and 1996] is based upon voluntarily filed tax
returns.
The taxpayer has not filed delinquent returns for 2000
and 2001. This precluded discussion of collection
alternatives.
* * * * * * *
The taxpayer did not raise any relevant issues to
challenge the appropriateness of the NFTL and none of
the conditions for considering withdraw [sic] of the
NFTL exist in this case.
The taxpayer has raised only frivolous arguments.
During the hearing, the taxpayer was unwilling to
discuss the legitimate issues.
The taxpayer did not raise any other relevant issues.
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Last modified: May 25, 2011