Patrick M. Shannon - Page 13

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               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                





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