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Summary of Determination
The Notice of Intent to Levy and the Notice of Federal
Tax Lien were issued properly.
An attachment to the notice of determination under sections 6320
and 6330 issued to each petitioner stated in pertinent part:
SUMMARY AND RECOMMENDATION
The issuance of the Notice of Intent to Levy was appro-
priate. The filing of the Notice of Federal Tax Lien
was also appropriate.
BRIEF BACKGROUND
The Notice of Intent to Levy (“Letter 1058”) was issued
12/15/2004. Internal Revenue Code 6330 provides for a
Collection Due Process hearing for requests made within
30 days of the issuance of the Notice of Intent to
Levy. Your request for a hearing was received on
1/5/2005 and is considered timely.
A Notice of Federal Tax Lien Filing (“NTFL”) and Your
Right to a Hearing under IRC 6320 was mailed to you by
certified mail on 12/29/2004. This letter notified you
that you had until 2/4/2005 to make a timely request
for a hearing. Your request for a hearing was received
on 1/18/2005 and is considered timely.
You had the opportunity to raise any relevant issues
relating to the unpaid tax, the Letter 1058 and the
NFTL at a Collection Due Process hearing. Appeals
Settlement Officer * * * conducted your requested
hearing on 5/6/2005, via telephone. You were offered
an opportunity to meet in person. * * * [The settle-
ment officer] had no prior involvement with the tax
liability at issue.
Basis for the Tax Liability
The liability is based upon a tax court decision.
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Last modified: November 10, 2007