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The petition in this case was filed in response to a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330 (notice of determination). Pursuant to section
6330(d), petitioner seeks review of respondent’s proposed levy
action with respect to her income tax liabilities for 1993, 1994,
and 1995. The issue for decision is whether respondent’s
determination to proceed with collection action was an abuse of
discretion.
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. At the time the
petition was filed, petitioner resided in New York, New York.
Earlier Contact With the Internal Revenue Service
Petitioner failed to timely file her tax returns for 1993,
1994, and 1995, and she filed them without full remittance. In
addition to the years under consideration, petitioner has unpaid
tax liabilities for the period 1988 through 1992. Over several
years, beginning in 1994, petitioner submitted nine offers-in-
compromise (OIC) which were rejected for one reason or another.
Petitioner feels that many employees of the Internal Revenue
Service (IRS) with whom she came into contact were insulting,
incompetent, or “threatening”.
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