Said Jumaa - Page 8

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               count.  Referred him to the page of the appointment                    
               letter which explained collection alternatives and what                
               is required in order for him to be eligible.  The                      
               taxpayer had no specific reason for not having filed                   
               returns, and no financial information was submitted.                   
               Therefore, the taxpayer was not eligible for a collec-                 
               tion alternative.                                                      
               The taxpayer raised the issue of the liability to the                  
               extent mentioned above.  There were no other issues                    
               raised by the taxpayer.                                                
               3.  Balancing of need for efficient collection with                    
               taxpayer concern that the collection action be no                      
               more intrusive than necessary.                                         
               The issuance of the Notice of Intent to levy is sus-                   
               Although less intrusive alternatives such as offers and                
               installment agreements exist, the taxpayer’s failure to                
               file all returns, and submit requested financial infor-                
               mation balance against them; and so while more intru-                  
               sive, the Government’s proposed levy action is appro-                  
               priate and the action is sustained.  [Reproduced liter-                
               In reviewing respondent’s examination file with respect to             
          petitioner’s taxable year 1998, respondent’s counsel discovered             
          that that file shows that the notice of deficiency with respect             
          to petitioner’s taxable year 1998 that respondent mailed to                 
          petitioner at his last known address was returned to respondent             
          by the U.S. Postal Service because it was unclaimed.                        
               The Court may grant summary judgment where there is no                 
          genuine issue of material fact and a decision may be rendered as            
          a matter of law.  Rule 121(b); Sundstrand Corp. v. Commissioner,            
          98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994).                 

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