- 4 -
notice of intent to levy, petitioner timely filed Form 12153,
Request for a Collection Due Process Hearing (petitioner’s Form
12153), and requested a hearing with respondent’s Appeals Office
(Appeals Office).3
On March 15, 2006, a settlement officer with the Appeals
Office (settlement officer) held an Appeals Office hearing with
petitioner with respect to the notice of intent to levy. At that
hearing, petitioner indicated that he was not liable for peti-
tioner’s unpaid liabilities for 1995 and 1998.
On April 5, 2006, the Appeals Office issued to petitioner a
notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). That notice
stated in pertinent part: “Collection is sustained. No collec-
tion alternatives were offered for consideration by Appeals.” An
attachment to the notice of determination stated in pertinent
part:
SUMMARY
* * * * * * *
The liabilities arose from your failure to file returns
for 1995 and 1998. You were sent a Statutory Notice of
Deficiency. You had a prior opportunity to appear at
an Appeal’s conference and an opportunity to petition
the US Tax Court. Therefore, the underlying liability
issue is precluded from this determination under Treas.
Reg. 301.7122 and IRC §6330.
3Petitioner apparently attached a document to petitioner’s
Form 12153 that is not part of the record in this case.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: November 10, 2007