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Summary of Determination
After discussion of the Notice of Intent to Levy during
a phone conference with the taxpayer, review of the
compliance case file, master file records, and any
information submitted by the taxpayer, a determination
was made to sustain the Notice of Intent to levy. The
taxpayer has not filed returns for 1999, 2000, 2001,
2002, 2003, 2004 and 2005, and did not submit the
requested financial information in order to be eligible
for a collection alternative. Therefore, the tax-
payer’s case is being returned to the compliance func-
tion for the appropriate action.
An attachment to the notice of determination stated in pertinent
part:
SUMMARY AND RECOMMENDATION
After discussion of the Notice of Intent to Levy during
a phone conference with the taxpayer, review of the
compliance case file, master file records, and any
information submitted by the taxpayer, a determination
was made to sustain the Notice of Intent to levy. The
taxpayer has not filed returns for 1999, 2000, 2001,
2002, 2003, 2004 and 2005, and did not submit the
requested financial information in order to be eligible
for a collection alternative. Therefore, the tax-
payer’s case is being returned to the compliance func-
tion for the appropriate action.
BRIEF BACKGROUND
The taxpayer failed to file the tax return for 1998 as
required. The return was subsequently prepared by
substitute for return processing. The Notice of Intent
to Levy was issued November 23, 2005. Form 12153
request for hearing was received by the Service timely
on December 20, 2005.
DISCUSSION AND ANALYSIS
1. Verification of legal and procedural requirements;
Based on review of the compliance file and computer
records, all requirements of applicable law, regulation
or administrative procedure appear to have been met.
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Last modified: November 10, 2007