- 4 -
July 13, 2005, Alan again contested petitioner’s underlying tax
liability. He stated that he had recently discovered documentary
evidence that would substantiate certain claimed business
expenses that respondent had previously disallowed. Alan asked
to be allowed to show this new evidence.
By letter dated July 20, 2005, the Appeals officer
reiterated that she could not consider petitioner’s underlying
tax liability; she stated that if petitioner did not present a
collection alternative plan by August 5, 2005, she would issue a
determination letter on the basis of information available to
her. In a letter dated July 25, 2005, Alan stated that he
believed petitioner was entitled to audit reconsideration on the
basis of his newly discovered evidence, but that all his tax
records relating to the appeal had been taken in an IRS raid of
his home on July 21, 2005. He requested a face-to-face hearing
and audit reconsideration, but only after his tax records were
returned by the IRS. Petitioner never proposed any collection
alternative to the proposed levy and never submitted requested
financial information necessary for Appeals Office consideration
of a collection alternative.
By Notice of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330 (the notice), dated September 7,
2005, the Appeals Office sustained the proposed levy. An
attachment to the notice explained that the Appeals Office was
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011