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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.
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