- 6 -
documents Mr. and Mrs. Harris previously submitted supporting the
second OIC--i.e., Forms 433-A, Collection Information Statement
for Wage Earners and Self-Employed Individuals, or the medical
records from the three doctors referred to in the body of the
second OIC; or the income and expense worksheets.5
On November 24, 2003, respondent issued Mr. and Mrs. Harris
a Notice of Determination Concerning Collection Action(s) Under
Section(s) 6320 and/or 6330 determining that the NFTL would not
be withdrawn.
OPINION
Section 6320 provides that the Secretary shall furnish the
person described in section 6321 with written notice (i.e., the
hearing notice) of the filing of a notice of lien under section
6323. Section 6320 further provides that the taxpayer may
request administrative review of the matter (in the form of a
hearing) within a 30-day period. The hearing generally shall be
conducted consistent with the procedures set forth in section
6330(c), (d), and (e)--which provide for, among other things, the
conduct of the hearing, the making of a determination, and
jurisdiction for court review of the section 6330 determination.
Sec. 6320(c).
5 Respondent submitted an affidavit of the settlement
officer listing the materials he reviewed before the
determination was made in this case. Neither the settlement
officer nor any other IRS employee testified at trial.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011