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Background
This is an appeal from respondent’s determination upholding
the proposed use of a levy to collect petitioners’ unpaid Federal
income tax liabilities for 2001 and 2002. Petitioners resided in
Oakhurst, Oklahoma, when the petition was filed.
On July 2, 2005, respondent sent petitioners a Final Notice
of Intent to Levy and Notice of Your Right to a Hearing for the
years at issue. Petitioners timely submitted a Form 12153,
Request for a Collection Due Process Hearing. In their request,
petitioners asserted that a levy would be “devastating” and
requested payment of their tax liabilities through an installment
agreement.
On September 13, 2005, respondent sent petitioners a letter
acknowledging petitioners’ request for a section 6330 hearing.
On May 1, 2006, Settlement Officer Greg Clark (Officer Clark)
sent petitioners a letter scheduling a telephone conference on
May 23, 2006, to discuss collection alternatives. In addition,
Officer Clark requested that petitioners produce a Form 433-A,
Collection Information Statement for Wage Earners and Self-
Employed Individuals (Form 433-A); Form 1040, U.S. Individual
Income Tax Return, for 2004 and 2005 (returns); proof of
estimated payments for 2005 and 2006; and copies of bank
statements for all accounts in petitioners’ name or held for
their benefit for the most current 3 months (bank statements).
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Last modified: November 10, 2007