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* 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You have not requested the NFTL be withdrawn.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.
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Last modified: November 10, 2007