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Collection Information Statement for Wage Earners and Self-
Employed Individuals, which asks the taxpayer to provide certain
financial information. The settlement officer indicated that if
petitioner did not provide the tax return and Form 433-A by
November 28, 2005, respondent would sustain the proposed
collection action. The settlement officer did not receive the
requested documents by that date.
On December 22, 2005, respondent issued petitioner a notice
of determination sustaining the proposed levy. The notice states
that petitioner failed to file the 2004 tax return or submit the
Form 433-A. It also states that the settlement officer verified
that applicable legal and administrative requirements had been
met.
On or about December 23, 2005, petitioner sent a letter to
the settlement officer in response to the notice of
determination. The letter states that petitioner mailed the 2004
tax return and the financial information on November 28, 2005.
Enclosed with the letter were a signed 2004 tax return and a Form
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Last modified: May 25, 2011