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On March 15, 2006, the Appeals Office issued to petitioner a
notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). That notice
stated in pertinent part:
Summary of Determination
You failed to provide any collection alternatives or
information needed to resolve the lien issue. Collec-
tion is sustained.
An attachment to the notice of determination stated in pertinent
part:
SUMMARY
You requested a hearing under IRC 6320 to dispute the
filing of a Notice of Federal Tax Lien for the periods
shown above [petitioner’s taxable years 1995, 1996,
1997, 1999, and 2000]. You wished to raise the issue
of the underlying tax liability and have your returns
reconsidered.
Our determination is that the lien is sustained.
BRIEF BACKGROUND
* * * [The settlement officer] offered a conference to
the taxpayer via a substantive contact letter. The
taxpayer’s representative responded to the letter with
a telephone call. During this call the representative
was advised that the underlying liability issue is
precluded because the taxpayer received his Statutory
Notice of Deficiency with the right to appeal on all
periods. Furthermore, the IRS had granted a reconsid-
eration of the liability previously, which resulted in
no change to the tax. The representative was given
additional time to submit a valid alternative to fur-
ther collection action. The representative agreed that
if he was unable to provide information necessary to
consider alternatives by February 28, 2006, * * * [the
settlement officer] would issue a determination.
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Last modified: May 25, 2011