- 4 -
Petitioners submitted a completed Form 12256 on April 6,
2004.4 By signing the form, each petitioner acknowledged:
I’ve received a resolution with the Internal Revenue Service
regarding the tax and tax period that my hearing request
concerned and I’m satisfied that I no longer need a hearing
with Appeals. Therefore, I withdraw my request for a
Collection due Process (CDP) Hearing under * * * IRC Section
6330, notice and opportunity for a hearing before a levy
* * *
I understand that by withdrawing my request:
• I give up my right to a Collection Due Process Hearing
with the Office of Appeals. I understand that the
Office of Appeals will not issue a Notice of
Determination with respect to the tax and tax period
the hearing request concerned.
• I give up my right to seek judicial review, in the Tax
Court or a U.S. District Court, of the Notice of
Determination that the Office of Appeals would have
issued as a result of the Collection Due Process
Hearing, as the Office of Appeals will not issue a
Notice of Determination.
• I give up my right to have the Office of Appeals retain
jurisdiction with respect to any determination that it
would have made as a result of the Collection Due
Process Hearing.
• The suspension of levy action and the suspension of the
statute of limitations on the period of collection, as
required under the provisions of IRC Sections 6320 and
6330, are no longer in effect upon the receipt by
Internal Revenue Service (IRS) of this withdrawal.
• I have the right to request a hearing with the Office
of Appeals that is equivalent to a Collection Due
Process Hearing without judicial appeal to the Tax
Court or a U.S. District court under IRC Section 6320
or 6330.
• I do not give up any other appeal rights that I am
entitled to, such as an appeal under the Collection
Appeals Program (CAP).
4The Apr. 6, 2004, Form 12256 pertained to 2002.
Petitioners stipulated that they also executed a Form 12256 for
2001.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007