- 7 -
On September 21, 2004, Victoria Osborn (Ms. Osborn) faxed
two similar letters from Mr. Jones’s office to the settlement
officer: “[T]o provide you with the information the taxpayer
wants considered regarding the proposed collection action.” In
pertinent part, the letters state that (1) the assessments of
taxes for 1996 and 1997 were untimely and (2) petitioners are
considering collection alternatives for 1998 and 1999 but require
additional documentation. The letters ask for a copy of the
“Administrative/Examination File for 1999”, the “ICS History”,
and the statutory notice of deficiency and proof of its mailing.
On September 22, 2004, at the time scheduled for the
hearing, the settlement officer telephoned petitioners’ counsel’s
office. Someone in the office conveyed a message to her from
petitioners’ counsel that the correspondence received on the
previous day was to serve as the hearing.
Determinations
On January 14, 2005, Appeals issued a “Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330” (notice) with respect to each of the Forms 12153.
The notices sustain the filing of all of the liens and all of the
proposed levy actions. Each notice is accompanied by an
attachment, wherein the settlement officer sets forth the
analysis leading to her conclusion that the collection actions
should be sustained. The analysis in each attachment is similar,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007