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that interest would be assessed as provided by law. Petitioner
and respondent both signed and dated the stipulated decision.
On June 13, 2005, respondent sent petitioner a notice of
intent to levy, advising petitioner that respondent intended to
proceed with collection by levy with regard to petitioner’s
unpaid income tax liability for the tax year 1999. Respondent
advised petitioner that petitioner could request a hearing with
respondent’s Office of Appeals.
Petitioner requested a collection due process hearing for
the tax year 1999, which was held by telephone on November 7,
2005. In his request for the hearing, petitioner indicated that
he did not agree with the proposed levy action because of
“financial hardship, low wages, divorce, bankruptcy, child
support and multiple lawsuits.” During the hearing, petitioner
and the Appeals officer explored collection alternatives.
Petitioner stated that he would be willing to pay $50 per month
until the 1999 tax obligation was paid. Petitioner explained
that he was earning $10 per hour as a hotel purchasing clerk,
that he rented his housing, and that he had very few assets. At
the conclusion of the telephone conversation, the Appeals officer
provided petitioner with Form 433-D, Installment Agreement. In
addition to showing the $2,242.31 petitioner owed for 1999, the
proposed installment agreement the Appeals officer prepared
included the tax year 2004 because respondent’s records showed
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Last modified: November 10, 2007