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The offer was investigated, but found not to be accept-
able, since you have sufficient equity in real property
and other assets to pay the amount due in full. You
and your representative were advised of the findings
and given opportunity to provide additional information
concerning the value of the assets, but did not do so.
Therefore, your offer cannot be recommended for accep-
tance. No other collection alternatives were proposed
to resolve your tax obligations or secure the govern-
ment’s interest in lieu of the Notice of Federal Tax
Lien.
DISCUSSION AND ANALYSIS
Transcripts and the case history verify that:
1) the taxes at issue were assessed in accor-
dance with IRC Section 6201, and that notice
and demand for payment was mailed to your
last known address timely in accordance with
IRC Section 6303.
2) there were balances due when the Collection
Due Process notice was issued, as required by
IRC Section 6322 and 6331(a), and that a levy
source had been identified.
3) IRC 6320(a)(2) requires that taxpayers be
notified of filing of a Notice of Federal Tax
Lien within five days of the date it is
filed. The record shows that this notice was
issued timely in accordance with the law.
4) Collection Due Process Notice was sent by
certified mail, return receipt requested, to
your last known address, which is the same as
that on your request for hearing.
5) The Automated Collection staff attempted to
resolve your case, but was unable to do so.
Therefore, your file was forwarded to Appeals
promptly upon receipt of your hearing re-
quest.
6) internal account transaction codes were en-
tered to place your accounts in suspended
status pending the outcome of the due process
hearing.
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Last modified: November 10, 2007