- 3 - tax year.2 On the same date, the Appeals Office also issued to petitioner a “Decision Letter Concerning Equivalent Hearing Under Section 6320 and/or 6330 of the Internal Revenue Code” (the decision letter), which states that it relates to petitioner’s 1991 tax year but is otherwise essentially identical to the Notice of Determination.3 The Notice of Determination and the decision letter conclude identically that the required procedures had been followed for the levy on the State tax refund. The Notice of Determination and the decision letter state identically: Although the liability is fully satisfied, you did not agree with our assessments, yet offered no substantive evidence, arguments, or legal authority, to support your position. I advised you to file * * * [a Form] 843 [Claim for Refund and Request for Abatement] claim, since there are no other collection alternatives necessary. The action by Compliance to levy has been sustained. 2 An attachment to the Notice of Determination states that because petitioner never received a Notice of Intent to Levy for 1992, “that year is not part of this hearing”. 3 Apparently, the decision letter was issued for 1991, rather than a notice of determination, on the ground that petitioner had timely failed to request a hearing with respect to collection action relating to her 1991 tax year. Respondent alleges that on Oct. 21, 2002, he issued to petitioner, with respect to her 1991 tax liability, a Notice of Intent to Levy and Notice of Your Right to Request a Hearing Under Section 6330 and that petitioner did not request a hearing with respect to this notice.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011