- 3 -
On September 11, 2006, respondent issued petitioner a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing in
connection with petitioner’s unpaid Form 940 and Form 941 tax
liabilities. Petitioner timely submitted a Form 12153, Request
for a Collection Due Process Hearing. In its request, petitioner
stated that “no explanation has been provided of the reason for
the levy nor a computation of amount for which a levy is
intended.”
On January 17, 2007, Settlement Officer Marilyn Ganser
(Appeals officer) held a telephone hearing with petitioner’s
representative, Donald A. Statland (Mr. Statland). At the
hearing, the Appeals officer informed Mr. Statland that
petitioner had failed to file its Form 941 tax returns for the
quarters ending June 30 and September 30, 2006. The Appeals
officer also explained that petitioner had filed no Form 1120,
U.S. Corporation Income Tax Return, since the inception of its
business. Additionally, the Appeals officer noted that
petitioner’s president, Andrew Otto, had not filed a Form 1040,
U.S. Individual Income Tax Return, since 1998. The Appeals
officer gave petitioner a January 31, 2007, deadline to provide a
current financial statement and to file all of the above-
mentioned delinquent returns. After the hearing, the Appeals
officer sent Mr. Statland copies of the returns respondent
prepared under section 6020(b). Petitioner did not file the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: March 27, 2008