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There is no indication that Mr. Hunter provided the settlement
officer with a Form 433-A or the financial information requested
therein.
The settlement officer and Mr. Hunter scheduled a telephone
hearing for June 1, 2005. Mr. Hunter called the settlement
officer on that day, but the settlement officer had stepped out
of her office. Mr. Hunter left a message, and the settlement
officer returned his call shortly thereafter. The settlement
officer left a message with a person who identified himself as
Mr. Hunter’s father, asking Mr. Hunter to return her call. It is
not clear whether Mr. Hunter received this message. In any
event, the settlement officer and Mr. Hunter did not speak by
telephone.
In August 2005, respondent issued a notice of determination
denying Mr. Hunter relief from the notice of Federal tax lien
filing and the proposed levy action. The notice of determination
states: (1) Mr. Hunter failed to provide requested financial
information; (2) the settlement officer determined, on the basis
of the best information available, that the requirements of
applicable law or administrative procedures had been met; and
(3) respondent’s proposed collection actions balance the need for
efficient collection of tax with the intrusiveness of the
actions. Mr. Hunter timely petitioned the Court for review of
the notice of determination.
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Last modified: May 25, 2011