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Background
This is an appeal from respondent’s determination upholding
the proposed use of a levy to collect petitioner’s unpaid Federal
income tax liabilities for 1999, 2000, 2003, and 2004.
Petitioner resided in Hominy, Oklahoma, when the petition was
filed.
Petitioner filed income tax returns for 1999, 2000, 2003,
and 2004. Petitioner did not pay all of his reported tax
liabilities. Respondent assessed the tax owed. On May 1, 2006,
respondent sent petitioner a Final Notice of Intent to Levy and
Notice of Your Right to Hearing for the years at issue.
Petitioner timely submitted a Form 12153, Request for a
Collection Due Process Hearing. In his request, petitioner
asserted that a levy would cause him “irreparable harm” and
requested payment of his tax liabilities through an installment
agreement.
On August 16, 2006, Settlement Officer Norman E. Chapman
(Officer Chapman) sent petitioner a letter acknowledging
petitioner’s request for a section 6330 hearing and scheduled a
telephone conference on September 18, 2006, to discuss collection
alternatives. Before the conference, Officer Chapman requested
that petitioner produce a Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals, and
proof of estimated tax payments for 2005 and the first and second
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Last modified: November 10, 2007