- 4 - 6320 (2004 NFTL) relating to 1997.1 On October 13, 2004, petitioner timely filed a Form 12153, Request for a Collection Due Process Hearing (2004 request), but he did not set forth any issues relating to his 1997 liability. The settlement officer scheduled a hearing for February 2, 2005 (2005 hearing), but petitioner failed to appear. The 2005 hearing was rescheduled for February 14, 2005. On February 13, 2005, the settlement officer received a letter in which petitioner stated he was withdrawing “[his] collection due process appeal”. On February 14, 2005, the settlement officer sent petitioner a Form 12256, Withdrawal of Request for Collection Due Process Hearing, but petitioner refused to sign the form. The settlement officer then rescheduled the 2005 hearing for March 25, 2005, and, in a letter dated March 18, 2005, informed petitioner that he was “previously provided with an opportunity to challenge this liability * * * in 2002 [and] the issue of liability cannot be considered”. The 2005 hearing was held via telephone on March 25, 2005, and petitioner was precluded from challenging the underlying liability. On May 3, 2005, respondent issued petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (2005 notice of determination). 1 The record does not indicate why respondent failed to proceed with the proposed collection action after issuing the 2003 notice of determination or why the 2004 NFTL was necessary.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011