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Opinion. On June 12, 2006, the Court issued an Order denying
that motion.
On July 7, 2006, the Appeals Office issued to Mr. Gazi and
Ms. Gazi’s estate a notice of determination concerning collection
action(s) under section 6320 and/or 6330 (notice of determina-
tion) with respect to the notice of intent to levy. That notice
stated in pertinent part:
Summary of Determination
All required legal procedures were followed in issuing
the Notice of Intent to Levy and advising you of your
appeal rights. Levy action in this case balances the
need for efficient collection of taxes with the legiti-
mate concern that any collection action be no more
intrusive than necessary. Since you failed to supply
any information for the conference held 05/15/2006, an
alternative to collection action could not be dis-
cussed. Further your challenge to the liability has
been denied by the Tax Court, thus waiting for your
appeal of that decision is not acceptable as an alter-
native to collection action without at least the finan-
cial information requested for review. The action by
the Compliance Division will be fully sustained.
You are being notified of this determination in writing
and your right to judicial review. [Reproduced liter-
ally.]
An attachment to the notice of determination stated in pertinent
part:
Type of Taxes: 1040
Tax Period(s): 12/1983 12/1984 12/1985 12/1986
12/1987 12/1988 12/1989
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