- 12 - I. SUMMARY AND RECOMMENDATION You, Mohamed Gazi, (“the taxpayer”) requested a hearing before Appeals under the provisions of Internal Revenue Code (“IRC”) Section 6330 for the tax periods listed above. On a letter attached to the form 12153 you stated in part: You dispute the liabilities which are the result of a decision by the United States Tax Court on July 8, 2003. You then detailed your appeals thru the tax court system and state an alternative will be requested when and if the assessments are sustained. You appealed the notice of intent to levy 23 days after receiving letter 1058. It is a timely appeal. We recommend your appeal regarding the notices of intent to levy be denied. All required legal proce- dures were followed in issuing the notice of intent to levy, and in advising you of your appeal rights. You failed to provide financial information and supporting documentation to the Settlement Officer in order to determine the appropriate collection alternative. You asked for and were granted a delay to supply the infor- mation and still did not have the information at the time of the rescheduled conference. You asked for another extension of time to finish the information, this was denied as a delaying tactic. Your alternate position that the tax is not owed and thus no action should take place is also denied. The Tax Court has held the taxes are legally due. Since an alternative could not be agreed upon, levy action in this case balances the need for efficient collection of taxes with the legitimate concern that any collection action be no more intrusive than necessary. II. BRIEF BACKGROUND You owe $1,678,803.28 for the above tax periods. You are in full compliance for all other years thru 2005. The balance due is a result of a self assessed return with agreed audit assessments by the Service for all years. You are now challenging the liability in an attempt to have the Tax Court decision reverses. On 03/27/2006 I issued a letter to you at your last known address, outlining the due process provisions and general Internal Revenue Manual guidelines regardingPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: March 27, 2008