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On September 12, 2005, respondent issued to Mr. Gazi a
notice of intent to levy and notice of your right to a hearing
with respect to his taxable years 1983 through 1989 (notice of
intent to levy).
On October 6, 2005, Ms. Ciraolo submitted to respondent on
behalf of Mr. Gazi and Ms. Gazi’s estate Form 12153, Request for
a Collection Due Process Hearing (Form 12153), and requested a
hearing with respondent’s Appeals Office (Appeals Office). (For
convenience, we shall refer to Form 12153 that Ms. Ciraolo
submitted to respondent on behalf of Mr. Gazi and Ms. Gazi’s
estate as Mr. Gazi’s Form 12153.) In Mr. Gazi’s Form 12153, Mr.
Gazi and Ms. Gazi’s estate indicated disagreement with the notice
of intent to levy. An attachment to Mr. Gazi’s Form 12153 stated
in pertinent part:
Grounds for Request:
1. Taxpayers dispute these liabilities, which are the
result of a decision entered by the United States
Tax Court on July 8, 2003. Mohammed A. Gazi and
the Estate of Raees I. Gazi, Deceased, Mohammed A.
Gazi, Personal Representative, Docket No. 7950-98.
Taxpayers filed a motion to vacate this decision
on March 12, 2004. The Court denied the motion
and Taxpayers’ moved to reconsider this decision
on August 29, 2005. In response to Taxpayers’
motion, this Court ordered the Service to respond
on or before October 6, 2005.
If the Court ultimately rejects the motion, Tax-
payers will appeal the Court’s decision to the
United States Court of Appeals. Taxpayers request
that the Service withhold any enforcement action
pending resolution of their motion and appeal.
Attached hereto as Exhibit 2 are the Motion for
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Last modified: March 27, 2008