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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.
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Last modified: November 10, 2007