- 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 was
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011