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Mather that he needed to submit information regarding the stock,
such as the fair market value, in writing and that a revenue
officer would make a determination regarding the sale of the
stock. Petitioners did not submit the required information
regarding the fair market value of the stock. Respondent did not
sell the stock accounts and made no determination regarding
petitioners’ request.
On May 8, 2002, the Appeals officer issued to petitioners a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (the notice of determination). In the
notice of determination, the Appeals Office determined that
petitioners were precluded from challenging their underlying tax
liabilities for 1993, 1994, and 1995, and that respondent’s
jeopardy levy would not be withdrawn.
OPINION
I. Introduction
If a person neglects or refuses to make payment of any
assessed Federal tax liability within 10 days of notice and
demand, the Secretary is authorized to collect the assessed tax
by levy on the person’s property. Sec. 6331(a). Section 6330(a)
provides, however, that no levy may be made on any property or
right to property of any person unless the Secretary has notified
such person in writing of the right to a fair hearing before
levy.
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