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The taxpayer has not filed delinquent returns for 2000
and 2001. This precluded discussion of collection
alternatives.
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.
III. Balancing the Need for Efficient Collection with the
Taxpayer’s Concern that the Collection Action be no
More Intrusive than Necessary
Has efficient tax collection been balanced with concern
regarding intrusiveness of the proposed collection
action?
IRC �6330 requires that the Settlement Officer consider
whether any collection action balances the need for
efficient collection of taxes with the taxpayer’s
legitimate concern that any collection action be no
more intrusive than necessary.
The taxpayer has not participated meaningfully in
trying to resolve his tax liability and has insisted
instead on using frivolous arguments, which have re-
peatedly been dismissed by the courts.
Appeals sustains Collection’s decision to issue a levy
as its next collection tool for resolving the tax-
payer’s tax account.
Summary of Decision
Appeals sustains Collection’s decision to levy to
collect the balance due on the taxpayer’s account. The
taxpayer is not in compliance with filing requirements
for individual income tax returns. The taxpayer raised
no relevant issues with regards to collection alterna-
tives.
On April 28, 2003, petitioner filed a petition with the
Court in response to the notice of determination and the decision
letter. Except for an argument under section 7521(a)(1), the
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Last modified: May 25, 2011