- 12 - You didn’t raise any issues or alternatives regarding the levy action. You didn’t submit financial informa- tion to determine your ability to pay. Without further information from you, we are sustaining the levy action. [Reproduced literally.] An attachment to the notice of determination stated in pertinent part: SUMMARY OF THE ISSUES The taxpayer sent the Service Center a letter of pro- test on 03-08-2004, arguing that the balances were in error. This was shortly after an Urgent notice and a notice of intent to levy, so the Service Center deter- mined this was a timely request for a collection due process hearing. The taxpayer argued that the balances were in error. The taxpayer stated that refunds and changes were misapplied. A hearing was offered to the taxpayer and two represen- tatives. A telephone and correspondence hearings were held with the representatives. The balance of the account was explained to them. I found nothing unusual in the postings of the 1999 liability and the payments by refunds from later years. The taxpayer and repre- sentatives raised no discussions regarding alternatives the levy action. The underlying liability is correct as posted to the account. RECOMMENDATION The levy action is sustained without other information to determine a lesser intrusive method of collection. BRIEF BACKGROUND The 1999 liability was first set up by Substitute for return and a statutory notice of deficiency. After the notice was defaulted, the taxpayer submitted a return with an increased liability. The self-corrected in- creases to the account were assessed. Later, there wasPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011