- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007