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received it, but he acknowledged receipt of other documents
mailed by respondent.
Respondent submitted a United States Postal Service (USPS)
Track and Confirm document verifying delivery of a postal package
to petitioner’s address on April 5, 2005. Respondent maintains
the notice of deficiency was enclosed in this package. The
actual receipt received upon delivery of the notice of deficiency
was no longer available in the records of the USPS.
Following the issuance of the notice of deficiency,
respondent began efforts to collect the liability for 2002.
These actions culminated in the issuance by respondent of a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing on
February 22, 2006. Petitioner timely filed a Form 12153, Request
For A Collection Due Process Hearing, and subsequently had a
telephone conversation with the Appeals officer assigned by
respondent. Respondent alleges that during this discussion
petitioner refused to address anything other than the underlying
liability for 2002. Petitioner did not submit any alternative
payment options to respondent’s Appeals officer.
On June 8, 2006, respondent issued to petitioner a Notice of
Determination Concerning Collection Action(s) relating to 2002
(notice of determination) sustaining the proposed intent to levy.
A timely petition for a review of the determination was filed in
this Court.
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Last modified: November 10, 2007