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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.
These issues were addressed during the conference held
05/15/2006.
BALANCING THE NEED FOR EFFICIENT COLLECTION WITH TAX-
PAYER CONCERN THAT THE COLLECTION ACTION BE NO MORE
INTRUSIVE THAN NECESSARY.
All required legal procedures were followed in issuing
the notice of intent to levy, and advising the taxpayer
of her appeal rights. The taxpayer was given the
opportunity to raise any relevant issues relating to
the unpaid tax. IRC Section 6330 requires that the
Appeals Officer consider whether any collection action
balances the need for efficient collection of taxes
with the legitimate concern that any collection action
be no more intrusive than necessary. The issue in this
case is whether a levy against the taxpayer’s assets is
appropriate. The taxpayer failed to provide the finan-
cial information with supporting documentation for the
conference. 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. [Reproduced literally.]
On July 13, 2006, Mr. Gazi and Ms. Gazi’s estate submitted
to respondent Form 433-A and an offer-in-compromise.
On May 10, 2007, after Mr. Gazi and Ms. Gazi’s estate filed
the petition in the instant case, the Court of Appeals for the
Eleventh Circuit affirmed the Gazis’ Tax Court decision. All
Cmty. Walk In Clinic v. Commissioner, 223 Fed. Appx. 949 (11th
Cir. 2007).7
7See supra note 5.
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