Paul L. Bowman - Page 9
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issued, as required by IRC Section 6322 and 6331(a),
and that a levy source had been identified.
3) before any levy action was initiated, notice of
intent to levy was issued in accordance with IRC
6331(d), which requires that taxpayers be notified
of the intention to levy no less than thirty days
before levy action is initiated.
4) Collection Due Process Notice was sent by cer-
tified mail, return receipt requested, to your
last known address.
5) The Automated Collection Site attempted to
resolve your case, but was unable to do so.
Therefore, your file was forwarded for appeals
consideration promptly upon receipt of your hear-
6) internal account transaction codes were entered
timely to place your accounts in suspended status
pending the outcome of the due process hearing
7) the Settlement Officer in this case has had no
prior involvement with you concerning the taxes at
issue in this due process proceeding, pursuant to
requirements of IRC 6330.
ISSUES RAISED BY THE TAXPAYER
1) no specific issues concerning liability or
collection procedures were raised.
Rather, you indicated only that you wished
a face-to-face hearing, which you intended
to tape record, and that details would be
disclosed at the hearing. You referenced
only the tax reform act of 1998 as the
reason for your hearing request.
Finding: Appeals is not obligated to address the
types of nonspecific issues contained in your
request, as you were advised in our conference
letter. You did not submit specific, legitimate
issues for discussion in writing to qualify for a
face-to-face conference. You were offered an
opportunity for a telephone conference, but failed
to contact the Settlement Officer.
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Last modified: November 10, 2007