- 8 - * Per review of computer transcripts, the CDP notice (Letter 3172) was sent by certified mail to your last known address, no later than 5 business days after the NFTL was recorded (IRC § 6320(a)). This was also the address shown on your CDP hearing request. The lien was filed on September 20, 2005 and the Letter 3172 was mailed on September 27, 2005, which is within 5 busi- ness days of the lien filing. * The collection period allowed by statute to collect these taxes has been suspended by the appropriate computer codes for the tax periods at issue. Transac- tion Code 520, has been posted for each of the taxes and periods listed on the NFTL as the date the IRS received the CDP hearing request. * Per transcript analysis, a CP504 notice, warning of a possible filing of a NFTL, was issued for the tax periods subject to the hearing at least 31 days prior to the NFTL filing. The notice was mailed on May 9, 2005. * There is no pending bankruptcy case, nor did you have a pending bankruptcy case at the time the CDP notice was sent (11 U.S.C. § 362(a)(6)). ! This Appeals employee has had no prior in- volvement with this taxpayer concerning the applicable tax periods before this CDP case. Issues Raised by the Taxpayer Challenges to the Existence or Amount of the Liability You have challenged the existence or the amount of the liability on the returns prepared by the IRS under IRC §6020(b). The underlying liability issue is precluded from this hearing. Furthermore, you have not prepared and submitted your own returns which would allow the IRS to adjust your tax liabilities. Challenges to the Appropriateness of the Collection Action You have not requested the NFTL be withdrawn. However, I have considered whether any of the criteria for allowing withdrawal of the lien existed in your case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007