Bobby J. Prater - Page 2

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               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               
               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             
               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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