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September 3, 2004, petitioner timely filed a Form 12153, Request
for a Collection Due Process Hearing, listing the following 13
grounds for his disagreement with respondent’s collection
actions: (1) Appropriateness of collection actions; (2)
collection alternatives; (3) impairment of spouse’s rights; (4)
amount of tax; (5) amount of interest; (6) amount of penalty; (7)
inadequacy of notice; (8) due process rights; (9) equal
protection rights; (10) other points to be made at hearing; (11)
adequacy of Appeals rights; (12) timeliness of notice of lien;
and (13) improper filing of lien.
Petitioner’s request for a hearing was assigned to
respondent’s Appeals Officer Horace Grantham, who sent a
September 22, 2004, letter to petitioner, tentatively, to
schedule an October 5, 2004, hearing and requesting petitioner,
within 10 days, to advise of his availability for such hearing.
By that same letter, Appeals Officer Grantham forwarded a Form
433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals, on which petitioner was to provide
information to enable the Appeals officer to consider collection
alternatives. Petitioner sent a letter, dated September 27,
2004, to the Appeals officer requesting that the October 5, 2004,
date be rescheduled to a date after October 26, 2004. The
Appeals officer replied by a September 29, 2004, letter
rescheduling a hearing for October 27, 2004. The hearing was
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Last modified: November 10, 2007