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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:
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Last modified: May 25, 2011