Mohammed Ali Gazi and Estate of Raees Iftekhar Gazi, Deceased, Mohammed Ali Gazi, Personal Representative - Page 12




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                           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 regarding                   






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Last modified: March 27, 2008