- 4 - complete the Form 433-A. You stated you previously file [sic] an Offer in Compromise that was rejected because you had the ability to full pay the taxes. I referred you to the Taxpayer Advocate Office; you stated they would not help you. It was explained to you that a Determination Letter would be issued sustaining the issuance of the levy. In the petition, petitioner states as his reason as to why he should be entitled to relief: In March of 1976, I was in an accident, in which I was hit by a car while riding my bicycle. I suffered numerous permanent and irreversible injuries. I have been injured, handicapped and limited every [sic] since. I certainly expect relief from the insurmountable penalty & interest charges. * * * OPINION Section 6331(a) provides that, if any person liable to pay any tax neglects or refuses to do so within 10 days after notice and demand, the Secretary can collect such tax by levy upon property belonging to such person. Pursuant to section 6331(d), the Secretary is required to give the taxpayer notice of his intent to levy and within that notice must describe the administrative review available to the taxpayer, before proceeding with the levy. See also sec. 6330(a). Section 6330(b) describes the administrative review process, providing that a taxpayer can request an Appeals hearing with regard to a levy notice. At the Appeals hearing, the taxpayer may raise certain matters set forth in section 6330(c)(2), which provides, in pertinent part:Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011