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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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Last modified: November 10, 2007