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Collections Action and Petitioners’ Offer-in-Compromise
On June 24, 2002, respondent filed a Notice of Federal Tax
Lien and Your Right to a Hearing Under IRC 6320 showing $1,346.96
owed for taxable year 1993 and $15,346.52 owed for taxable year
1994. Respondent sent to petitioners a Final Notice--Intent to
Levy and Notice of Your Right to a Hearing on June 27, 2002.
On August 19, 2002, petitioners mailed to respondent a Form
12153, Request for a Collection Due Process Hearing (CDP
hearing). Respondent notified petitioners by letter on September
19, 2002, that he had received petitioners’ request for a CDP
hearing and, in turn, had forwarded that request to his Appeals
Office.
On May 13, 2004,6 Appeals Officer Beverly A. Roberts (Ms.
Roberts) responded in writing to petitioners’ request for a CDP
hearing. Ms. Roberts informed petitioners that they could
request either a face-to-face meeting or a telephone conference.
Petitioners requested a telephone conference with Ms. Roberts for
their CDP hearing on May 27, 2004.
6 At trial, respondent acknowledged that for reasons
unbeknownst to him, no action had occurred on petitioners’ file
from September 2002 until May 2004. Our examination of the
record, however, indicates that respondent was notified on July
24, 2002, that petitioners were parties in a bankruptcy suit.
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Last modified: March 27, 2008