- 4 - By law, you are entitled to only one CDP Hearing under Internal Revenue Code Section 6330 for the unpaid taxes listed in our Notice of Intent to Levy. This letter preserves your right to a future CDP hearing should that become necessary. You don’t need to do anything further regarding this request. * * * * * * * * * * The law entitles you to a CDP Hearing, but the hearing would take place after the levy or seizure. The IRS later advised petitioners that the July 15, 2004, letter rescinding the notice of levy was issued in error. On May 6, 2005, petitioners and respondent’s Settlement Officer, Patrick S. Lin (Lin), had a face-to-face meeting to discuss petitioners’ hearing requests. During the meeting, petitioners expressed their intent to submit an OIC to settle their respective tax liabilities for 1994 through 2002. After the face-to-face meeting, on July 27, 2005, petitioners filed two separate OICs. The first offered to compromise petitioner’s individual 1994 through 1996 tax liabilities for $4,000. The second offered to compromise petitioners’ joint 1997 through 2002 tax liabilities for $16,000. Subsequently, petitioners filed amended OICs and increased the amounts of the offers to: (1) $6,250 for petitioner’s separate tax liabilities for 1989, 1993, 1994, 1995, and 1996 and (2) $18,500 for petitioners’ 1997 through 2002 joint tax liabilities (for a total offer of $24,750).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007