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provide Form 433-A or any other documentary evidence relating to
their financial status or their financial situation at and after
the respective times their returns for their taxable years 1998
through 2003 were filed.
On December 2, 2005, the Appeals Office issued to petition-
ers a notice of determination concerning collection action(s)
under section 6320 and/or 6330 (notice of determination). That
notice stated in pertinent part:
Summary of Determination
We have found that all legal and administrative re-
quirements for the action taken have been met. We have
also considered whether the collection action taken or
proposed balances the need for the efficient collection
of the taxes with the legitimate concern of the tax-
payer that any collection action be no more intrusive
than necessary. At this time, grounds for withdrawal
of the lien have not been established. The case will
be returned to the Automated Collection System (ACS)
for the appropriate actions.
An attachment to the notice of determination stated in pertinent
part with respect to petitioners’ taxable years 1998 through
2003:
SUMMARY AND RECOMMENDATION
The taxpayers did not present any information that
warrants withdrawal of the filed Notice of Federal Tax
Lien.
BRIEF BACKGROUND
This Appeals employee has had no prior involvement with
this taxpayer with respect to these liabilities in
either Compliance or Appeals.
In our letter dated September 13, 2005, we asked the
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Last modified: November 10, 2007