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On or about August 22, 2000, in response to petitioner’s
August 17, 2000 letter, respondent’s settlement officer sent a
letter to petitioner. That letter stated in pertinent part:
Your letter dated August 17, 2000, addressed to IRS
Appeals for documents and records has been forwarded
for processing to the IRS North Texas Disclosure Office
* * *. This is the responsible office for your re-
quest. * * *
On or about April 10, 2001, an Appeals officer with respon-
dent’s Appeals Office (Appeals officer) sent petitioner a letter
(Appeals officer’s April 10, 2001 letter). That letter stated in
pertinent part:
The District issued a Final Notice of Intent to Levy on
March 23, 2000 for taxes due for the years ended
December 31, 1992, 1993 and 1994 and a Civil Penalty
for the year ended December 3, 1998 [sic]. You re-
quested a Collection Due Process Hearing on April 7,
2000. Your case was forwarded to the Dallas Appeals
Office and was assigned to * * * [respondent’s settle-
ment officer]. * * * [Respondent’s settlement officer]
responded to your letter of August 17, 2000 in which
you requested documents and records and informed you
that this is the responsibility of the IRS’s Disclosure
Office.
Your case has been transferred to me.
* * * * * * *
Appeals has jurisdiction in this case to hear relevant
issues related to unpaid liability, challenges to the
appropriateness of collection actions, offers of col-
lection alternatives and challenges to the underlying
liability.
On Form 12153, Request for Collection Due Process, you
listed the year ending December 31, 1996. This year
was not included on the Final Notice.
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Last modified: May 25, 2011