- 10 - for payment was issued on 7/2/2001. Letter 1058 was sent 12/15/2005. The NFTL was filed on 12/28/2004. The Revenue Officer followed all administrative proce- dures in determining the NFTL should be filed. You raised no issues concerning IRS’ compliance with its procedures in filing in issuing the Letter 1058. You offered no collection alternatives. Balancing Efficient Collection With Intrusiveness of Proposed Action IRC §6320 and IRC § 6330 requires the Appeals Officer to consider whether any collection action balances the need for efficient collection of the unpaid taxes with the legitimate concern that such action be no more intrusive than necessary. It is my judgment that the filing of the NFTL and the proposed levy action appear to be no more intrusive than necessary for the effi- cient collection of the unpaid tax. IRS is justified in proceeding with the proposed levy action as it sees fit. [Reproduced literally.] Petitioners filed a petition with the Court with respect to the notice of determination under sections 6320 and 6330.2 In that petition, petitioners alleged: 4. The determination that the Notice of Intent to Levy and the Notice of Federal Tax Lien were issued properly is based upon the following errors: a. Error in concluding that the underly- ing tax liability had previously been considered by appeals thereby precluding Petitioners from having the liability considered again. 5. The law and facts upon which the Petitioners rely, as the basis of their case are as follows: 2Ms. Hollen did not file a petition with the Court with respect to the notice of determination under section 6015.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007