- 11 - face-to-face hearing and acknowledging that alternative collection methods needed to be explored at this meeting, and stating that he was not available for the telephone conference on April 28. On April 28, 2005, Ms. Dermody sent petitioners a letter to which she attached a copy of the Form 12153, and in which she advised petitioners that if they wanted a face-to-face hearing they must contact her within 15 days and describe the legitimate issues they wished to raise. Ms. Dermody also advised petitioners that they must complete a Form 433-A, Collection Information Statement for Wage Earners and Self Employed Individuals, and return it along with their 2003 and 2004 tax returns by May 13, 2005. On May 13, 2005, Mr. Summers sent Ms. Dermody a letter in which he raised the following issues: (1) That Ms. Dermody was a settlement officer, not an independent Appeals officer, and that it was improper for her to hold the hearing; (2) that respondent violated the “CDP statutes” by not holding a section 6330 hearing for more than 3 years from the date of the request; and (3) that petitioners did not have any tax liability for 1989 because the IRS improperly credited the payments from Commonwealth, and that, 5(...continued) his former attorney, Jerry Arthur Jewett, who had since been disbarred, may have made the request without sending petitioners a copy.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011