- 2 - Background Respondent sent to petitioner a Final Notice - Notice of Intent to Levy and Notice of Your Right to a Hearing and a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 with respect to unpaid tax that had previously been assessed for the 1994 tax year. Petitioner timely requested a hearing with respect to each notice. In a letter dated August 17, 2006, acknowledging petitioner’s hearing requests, respondent’s Appeals officer advised petitioner that a telephonic hearing was scheduled for September 21, 2006, at 11:30 a.m. The letter advised petitioner that the issues raised in her hearing requests are those that courts have determined are frivolous. However, the Appeals officer advised petitioner that she would be allowed a face-to- face hearing on any relevant, nonfrivolous issue, or a hearing via correspondence, if petitioner appropriately requested such a hearing within 14 days. The letter also advised petitioner that if she desired to pursue alternative collection methods, she should provide a Form 433-A, Collection Information Statement for Wage Earners and Self-Employed Individuals, and a signed tax return for the 2005 tax period. Petitioner did not call respondent at the scheduled time for the hearing, nor did she indicate in a timely fashion that such date and/or time was inconvenient.Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007