- 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Determination Concerning Collection Action(s) Under Section(s) 6320 and/or 6330 determining that the NFTL would not be withdrawn.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