Robert L. Perkins - Page 5




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          to $3,000.  The letter provided instructions for the filing of an           
          appeal of the disallowance.  Pursuant to the instructions,                  
          petitioner appealed the disallowance in the Letter 105C by means            
          of a letter to respondent dated May 17, 2002, in which he offered           
          his reasons for disagreeing, including a declaration that his               
          statements were true under penalties of perjury (Appeals                    
          request).                                                                   
               On August 10, 2002, before responding to petitioner's                  
          Appeals request, respondent sent petitioner a "Final Notice of              
          Intent to Levy and Notice of Your Right to a Hearing" (Notice of            
          Intent to Levy), notifying petitioner that respondent intended to           
          satisfy petitioner's outstanding 2000 tax liability by a levy,              
          and advising petitioner of his right to request a hearing.                  
          Petitioner timely requested a hearing on a Form 12153, Request              
          for a Collection Due Process Hearing, sent to respondent on                 
          September 6, 2002.  Petitioner's Form 12153 disputed both the               
          underlying tax liability and the "appropriateness of the                    
          collection action", in light of the fact that consideration of              
          his Appeals request was still pending.                                      
               At some point, petitioner's Appeals request was referred to            
          and considered by respondent's Office of Appeals.  On April 28,             
          2003, before any action was taken with respect to petitioner's              
          hearing request under section 6330, the Appeals Office issued               
          petitioner a written response to his Appeals request.  Treating             







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