- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007