- 12 - memorandum by the IRS regarding the issues surrounding petitioner’s stock acquisitions. On September 4, 2003, respondent mailed to petitioner a Final Notice of Intent to Levy with respect to petitioner’s 2001 tax liability. Petitioner’s counsel, Mr. Isaacson, wrote to respondent and requested an administrative hearing. Appeals Officer Lawrence Dorr conducted a telephonic hearing with Mr. Isaacson on December 3 and 5, 2003. Mr. Dorr declined to consider petitioner’s request for relief and issued Notices of Determination Concerning Collection Actions for the years at issue on January 15, 2004, and February 5, 2004, respectively. In the determination, Mr. Dorr found “there was no mechanism in the Collection Due Process venue for withholding collection in this circumstance”. Mr. Dorr did not review the underlying liability for the years at issue. Petitioner timely filed a petition for lien or levy action with the Court on February 18, 2004. On August 19, 2004, this case was set for trial during the January 24, 2005, Trial Session in Seattle, Washington. On October 27, 2004, respondent moved for a continuance and remand. On December 8, 2004, the Court retained jurisdiction and remanded this case to respondent’s Appeals Office for another administrative hearing to consider petitioner’s underlying tax liabilities for the years at issue.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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