Homer W. and Nancy L. Winans - Page 5

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          the TAS a Form 433-A, Collection Information Statement for Wage             
          Earners and Self-Employed Individuals.  In January 2004,                    
          respondent’s collection division complied with a TAS request to             
          reduce the amount that it was collecting from petitioner’s wages            
          to $500 per week.  At the time of trial, respondent continued to            
          collect approximately $500 per week from petitioner’s wages.                
               Respondent also mailed to petitioners Notices of Federal Tax           
          Lien Filing and Notice of Your Right to a Hearing Under Section             
          6320 for 1996-2001 and Notices of Intent to Levy and Notice Of              
          Your Right to a Hearing Under Section 6330 for 1999-2001.                   
          Petitioners timely filed with respondent’s Office of Appeals                
          (Appeals Office) a Form 12153, Request for Collection Due Process           
          Hearing, in response to each of the collection notices.                     
          Petitioners attached to each Form 12153 written statements                  
          containing only tax-protestor rhetoric.                                     
          D.   Events Leading to Respondent’s Collection Determinations               
               By letter to petitioners dated March 8, 2004, the Appeals              
          Office generally explained the administrative process and sent              
          Forms 4340, Certificate of Assessments, Payments, and Other                 
          Specified Matters, for the years 1996-2001.  By letter to                   
          petitioners dated May 24, 2004, respondent’s settlement officer             
          said that he had reviewed and rejected their claims, and that he            
          had verified that the assessments were proper by reviewing Forms            
          4340 for the years in issue.  He also said that petitioners would           
          have a brief period of time to present an alternative to the                

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