James Murden Wilcox - Page 4

                                        - 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.  * * *                                                        
               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