Michael D. Cornwell and Hilary J. Iker - Page 4




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                    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).                                 








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