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An attachment to the notice of determination stated in pertinent
part:
I. Verification of Legal and Procedural Requirements
With the best information available, the requirements
of various applicable law or administrative procedures
have been met.
IRC Section 6331(d) requires the taxpayer be notified
at least 30 days before a notice of levy can be issued.
The 30-day letter was sent on tax years ending
12/31/1990, 12/31/1991, 12/31/1992, 12/31/1994,
12/31/1996, 12/31/1997 and 12/31/2002 on February 7th
2005.
* * * * * * *
IRC 6330(c) allows the taxpayer to raise any relevant
issues relating to the unpaid tax or the proposed levy
at the hearing.
This Settlement Officer has had no prior involvement
with respect to these liabilities.
II. Issues Raised by the Taxpayer
Challenges to the Amount of the Liability
You did not challenge the amount of the liability.
III. Balancing Efficient Collection and Intrusiveness
IRC section 6330 require[s] that the Settlement Officer
consider [whether] the collection action balances the
need for efficient collection of taxes with the tax-
payer’s legitimate concern that any collection action
be no more intrusive than necessary.
Collection alternatives include full payment, install-
ment agreement, offer in compromise and temporary
suspension of collection based on financial hardship.
You submitted an offer in compromise and it was deter-
mined you had the ability to pay the taxes and your
offer was recommended for rejection. We also discussed
an installment agreement but you were not in agreement
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Last modified: March 27, 2008