Laura K. Davis, et al. - Page 7

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          Responses and Hearing                                                       
               On April 13, 2004, in response to the final notices and the            
          NFTLs, each petitioner filed with Appeals an Internal Revenue               
          Service (IRS) Form 12153, Request for a Collection Due Process              
          Hearing.  On those forms, petitioners commonly allege that there            
          exist “whipsaws” with related entities or persons.  Ms. Davis               
          alleges that she is an “innocent spouse”.  Mr. Jones signed the             
          Forms 12153 as each petitioner’s authorized representative.                 
               On June 18, 2004, in response to the Forms 12153, an Appeals           
          employee, Settlement Officer Michael A. Freitag (the settlement             
          officer), sent Mr. Jones a letter scheduling a hearing for July             
          19, 2004, with respect to all of the hearing requests.  Among               
          other things, the letter states that, if Mr. Jones wishes to                
          propose collections alternatives, such as an installment                    
          agreement or an offer-in-compromise, he must complete and submit            
          current financial statements, along with verification, prior to             
          the hearing date.  The hearing was rescheduled for August 24,               
          2004, but Mr. Jones failed to appear.  On September 7, 2004, the            
          settlement officer held a telephone conference with Mr. Jones.              
               On December 2, 2004, Appeals issued to each petitioner a               
          “Notice of Determination Concerning Collection Action(s) Under              
          Section 6320 and/or 6330” (notice).  The notices sustain the                
          filing of the lien and the proposed levy action.  Each notice is            

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