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On December 15, 2005, respondent mailed to petitioner a
notice of tax lien filing relating to the above assessed tax
deficiencies.
On February 6, 2006, respondent mailed to petitioner a
notice of intent to levy on petitioner’s property to collect the
above-assessed tax deficiencies.
On March 8, 2006, petitioner filed late a request for an
Appeals Office hearing regarding respondent’s December 15, 2005,
notice of tax lien filing, and on March 8, 2006, petitioner
timely filed a request for an Appeals Office hearing regarding
respondent’s notice of intent to levy.
Pursuant to petitioner’s request for an Appeals Office
collection hearing with regard to both the notice of tax lien
filing and the notice of intent to levy, respondent offered to
conduct with petitioner a consolidated collection hearing via
either a face-to-face meeting or a telephone call.
Petitioner, however, did not respond to the invitation for a
face-to-face meeting or for a telephone call, and respondent’s
Appeals officer concluded the collection hearing. Based on his
review of the administrative file, respondent’s Appeals officer
reached his conclusion regarding the notice of tax lien filing
and the notice of intent to levy.
With regard to the notice of tax lien filing, respondent’s
Appeals officer treated his review of the administrative file and
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Last modified: November 10, 2007