James E. Anderson and Cheryl J. Latos - Page 18




                                       - 18 -                                         
                              Attachment to Letter 3193                               

                                                  Date of Notice of                   
                Tax Form / Type    Tax Period      Federal Tax Lien                   
                     *      *      *      *      *      *      *                      
                      1040         12-31-1995         11-07-2003                      
                      1040         12-31-1996         11-07-2003                      
                      1040         12-31-1997         11-07-2003                      
                     *      *      *      *      *      *      *                      
               The IRS received from you Form 12153, postmarked 11-22-                
               2003.  This is a request for a Collection Due Process                  
               Hearing.  You filed this form in response to the Col-                  
               lection Department’s recordation of Notices of Federal                 
               Tax Lien against you relative to the above listed                      
               liabilities.  The statutes for collection of these                     
               liabilities were suspended during the hearing process                  
               because your request for a hearing was mailed prior to                 
               the deadline for timely filing as provided for in IRC                  
               section 6330. * * *                                                    
               The Settlement Officer in this case had no prior in-                   
               volvement with the liabilities in question.                            
               Verification that Law and Procedure were Followed                      
               Information in the administrative case file and related                
               computer records shows that the IRS followed law and                   
               procedure in this case. * * * The assessments in ques-                 
               tion were properly made under IRC section 6201, and                    
               notice and demand was sent to you as per IRC section                   
               6303.  You did not pay the liabilities.  The IRS gave                  
               you additional opportunities to pay the balances due                   
               voluntarily, but you failed to do so.  The Collection                  
               Department recorded the liens to protect the govern-                   
               ment’s interest.                                                       
               Relevant Issues Raised by the Taxpayer                                 
               On the Form 12153 you state “Not Self Employed IRC Sec.                
               3403 and 3102(b).”  The Federal Tax Lien will not be                   
               released until the full balances of all the tax years                  
               involved are paid in full.  At your hearing it was                     
               discussed that the equity in * * * [Ms. Latos’ resi-                   






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