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BRIEF BACKGROUND
On February 7, 2006, Settlement Officer Elissa Dellosso
sent you a letter giving you an opportunity for a
telephonic hearing for March 9, 2006. You were advised
in that letter that the underlying liability issue that
was raised in your CDP request was precluded from this
hearing, but that she would consider other collection
alternatives. Ms. Dellosso sent you a Collection
Information Statement to prepare and send back to her
by February 21, 2006. She did not receive it. On
March 6, 2006 you requested a postponement and a face
to face hearing, which was granted. On March 15, 2006
you appeared in her office and she conducted a face-to-
face hearing with you. You did not submit the Collec-
tion Information Statement and stated you wanted an-
other postponement because you had just hired a firm to
represent you. This request was denied because you had
sufficient time to obtain representation prior to the
original scheduled hearing date.
1. Verification - Legal and Procedural Requirements
a. General Verification Requirements
The assessment was properly made per IRC § 6201 for the
12/31/1995 and 12/31/1998 tax periods. A statutory
notice of deficiency was mailed to you via Certified
Mail on June 10, 2002. The administrative file shows
that on August 22, 2002 the US Tax Court ordered you to
perfect the petition and pay the fee by 11/15/2002.
You did not do so and the Court dismissed your case.
The notice and demand for payment letter was mailed to
your current address, within 60 days of the assessment,
as required by IRC § 6303.
There was a balance due when the CDP levy notice was
requested.
Ms. Dellosso verified the collection period allowed by
statute to collect these taxes has been suspended by
the appropriate computer codes for the tax periods at
issue.
There was no pending bankruptcy at the time the notices
were issued.
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Last modified: November 10, 2007