- 9 - 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- ing request. 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007