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2000 $ 43,959.00 Withholding $ 23,226.00
2001 $ 35,660.00 Withholding $ 21,019.00
2002 $ 53,753.00 Withholding $ 37,289.00
You were also assessed late filing penalty on these
years. Interest and failure to pay penalty continue to
accrue on the unpaid assessment.
Your lack of compliance is considered egregious. You
have not filed an income tax return since 1989. You
have made no estimated tax payments and have not had
sufficient withholding to cover the tax. You have not
been in compliance with the filing and payment require-
ments for 14 years, despite the fact that you have had
considerable income and you were able to set aside more
than $225,000 in pension and stocks and bonds in lieu
of filing and paying your taxes.
You have not supplied financial information to help us
resolve your account. You have not presented any
alternatives to the NFTL or future collection action,
including possible seizure of your assets.
Discussion and Analysis
Verification of Legal and Procedural Requirements
The requirements of applicable law or administrative
procedures have been met and the actions taken were
appropriate under the circumstances.
* I verified through transcript analysis that assess-
ment was made on the applicable CDP notice periods per
IRC § 6201 and the notice and demand for payment letter
was mailed to the taxpayer’s last known address, within
60 days of the assessment, as required by IRC § 6303.
* Per transcript analysis, there was a balance due when
the NFTL filing was requested. This balance is still
due.
* IRC § 6321 provides a statutory lien when a taxpayer
neglects or refuses to pay a tax liability after notice
and demand for payment. Transcripts of the account
show that the IRS issued notice and demand for each of
the tax periods involved and those periods remain
unpaid.
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Last modified: November 10, 2007