Richard Fransen - Page 7




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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