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DISCUSSION AND ANALYSIS
Verification - Legal and Procedural Requirements
a. General Verification Requirements -
Assessment was properly made per IRC � 6201 for each
tax and period listed on the CDP notice. The notice
and demand for payment letter was mailed to the tax-
payer’s last known address, within 60 days of the
assessment, as required by IRC � 6303. There was a
balance due when the NFTL filing was requested.
The collection period allowed by statute to collect
these taxes has been suspended by the appropriate
computer codes for the tax periods at issue. The
taxpayer had no pending bankruptcy case at the time the
CDP notice was sent.
This Appeals employee has had no prior involvement with
this taxpayer concerning the applicable tax periods
before the first CDP case on these periods.
The Service is required to make reasonable efforts to
contact the taxpayer before filing a Notice of Federal
Tax Lien (NFTL) to advise the taxpayer that a NFTL may
be filed if full payment is not made. Issuance of a
balance due notice in which a possible NFTL filing is
mentioned constitutes reasonable efforts
Case transcripts show the assessment and assessment
notice dates as follows:
Year Date of Assessment Date of Notice
1995 8/26/2002 8/26/2002
1996 8/26/2002 8/26/2002
1997 8/26/2002 8/26/2002
1999 8/26/2002 8/26/2002
2000 8/26/2002 8/26/2002
Letter 3172 was sent by certified mail to the tax-
payer’s last known address. Computer copies of Letter
3172 and NFTL were included in the case file submitted
to Appeals.
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Last modified: May 25, 2011