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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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Last modified: May 25, 2011