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Respondent issued to Ms. Latos the notice and demand for
payment required by section 6303(a) with respect to Ms. Latos’
unpaid 1998 liability.
On December 5, 2001, respondent issued to Ms. Latos a notice
of intent to levy and notice of your right to a hearing with
respect to, inter alia, her taxable year 1998 (1998 notice of
intent to levy).
On December 9, 2001, in response to the 1998 notice of
intent to levy, Ms. Latos mailed to respondent Form 12153,
Request for a Collection Due Process Hearing (Ms. Latos’ Form
12153 with respect to the 1998 notice of intent to levy), and
requested a hearing with respondent’s Appeals Office (Appeals
Office). In that form, Ms. Latos indicated that she did not
agree with the 1998 notice of intent to levy and gave the follow-
ing explanation for her disagreement: “IRS MUST COLLECT FROM THE
EMPLOYER AND HAS NO STATUTORY AUTHORIZATION TO COLLECT FROM THE
EMPLOYEE.” A two-page attachment to Ms. Latos’ Form 12153 with
respect to the 1998 notice of intent to levy stated in pertinent
part:
Taxpayer is an employee.
* * * * * * *
Taxpayers have also requested that the IRS seek techni-
cal advice on the provisions of TITLE 26 - INTERNAL
REVENUE CODE Subtitle C - Employment Taxes CHAPTER 24 -
COLLECTION OF INCOME TAX AT SOURCE.
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Last modified: November 10, 2007