- 4 -
reschedule the phone conference; and (3) informed petitioner that
if the Appeals Office did not receive any additional information
from petitioner, Appeals would review petitioner’s case based on
the information in petitioner’s file.
On February 9, 2006, Settlement Officer Feist called
petitioner at the phone number petitioner had provided. No one
answered Settlement Officer Feist’s call. Settlement Officer
Feist left a voice message stating (1) that he could not
determine that the assessments or proposed collection actions
were incorrect based on the information petitioner had provided,
and (2) that respondent would issue a notice of determination in
petitioner’s case.
Respondent issued to petitioner a Notice of Determination
Concerning Collection Action(s) under Section 6320 and/or 6330
(notice of determination) with respect to petitioner’s income tax
liabilities for 1992 and 1993. In the notice of determination,
respondent determined that the proposed levy should be sustained
and that petitioner “failed to file outstanding U.S. Individual
Income Tax Returns, failed to make payments on the amounts
assessed, and failed to submit a viable collection alternative”.
Petitioner timely filed a petition for lien or levy action
under section 6320(c) or 6330(d) regarding his 1992 and 1993 tax
liabilities. In the petition, petitioner raised several
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: November 10, 2007