Patricia Agnes Williams, Debbie Wales, Next Friend - Page 7

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          have an opportunity to dispute such tax liability.”  Sec.                   
               The parties agree that the IRS sent petitioner and her                 
          spouse Letter 1058, Final Notice of Intent to Levy and Notice of            
          Your Right to a Hearing, that they received a copy of the notice            
          of intent to levy and right to a hearing, and that they did not             
          request a hearing with Appeals.                                             
               Petitioner’s failure to request a hearing on the notice of             
          intent to levy is the deciding factor in this case.  “An                    
          opportunity to dispute a liability includes a prior opportunity             
          for a conference with Appeals that was offered either before or             
          after the assessment of the liability.”  Sec. 301.6320-1(e)(3),             
          Q&A E2, Proced. & Admin. Regs.                                              
               Section 301.6320-1(e)(3), Q&A-E7, Proced. & Admin. Regs.,              
          further explains that “Where the taxpayer previously received a             
          CDP Notice under 6330 with respect to the same tax and tax period           
          and did not request a CDP hearing with respect to that earlier              
          CDP Notice, the taxpayer already had an opportunity to dispute              
          the existence or amount of the underlying tax liability.”                   
               Petitioner could have challenged as improper, due to the               
          alleged failure of the IRS to mail to her a statutory notice of             
          deficiency, the assessment for 1990 income taxes at a section               
          6330 hearing offered in the notice of intent to levy.  Because              
          petitioner has had an opportunity to dispute the assessment in              

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