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levy notice of 16 January 04, which is unfair practice
[sic] requiring legal remedy.
Mr. Hunter’s case was assigned to respondent’s settlement
officer. The settlement officer sent Mr. Hunter a letter in
April 2005 requesting a Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals, which
instructs the taxpayer to provide certain financial information.
Mr. Hunter sent a letter to the settlement officer in May
2005, which states:
We offer three issues relevant to our CDP [hearing]
* * *:
(1) Collection Alternatives--Our Assets and Income
substantially outweigh our Expenses and Liabilities for
tax year 2002.
(2) Appropriateness of Collection Action--We strongly
and urgently object to the Lein [sic] Determination.
Because our 2002 tax form and supporting materials were
sent via certified mail, which was postmarked 09 April
2003. That being 6 days prior to the 15 April 2003
deadline. * * * Furthermore, our tax filing date was
erroneously reported as 07-07-03. This constitutes an
82 to 88 day time gap, which allowed us to be hit with
a $55,686.75 tax assessment plus interest and
penalties. Thus amounting to an overall tax liability
of $56,107.87 or more. Again, We respectfully disagree
with the ambiguous nature of said procedure.
(3) Spousal Defenses–Mrs. Alma Esteban Hunter, my
Wife, is a Permanent Resident of The United States.
She has a valid Green Card, A valid Social Security
Number, and legitimate employment. This has been duly
reported to the appropriate agencies. [Emphasis
omitted.]
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