- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007