- 5 - evidence to challenge and disprove the liability the IRS claims I owe.” Petitioner did not submit any of the requested information to the settlement officer. On October 12, 2006, the Appeals Office issued a notice of determination that the proposed levy action was appropriate and could proceed. Attached to the notice was a document summarizing the issues, the background, and the discussion and analysis supporting the determination. The following information was included in the attachment. 1. The Service mailed a notice of deficiency to petitioner for 2002, and he petitioned the Tax Court. Because he had a prior opportunity to appeal the underlying liability for 2002, he could not raise any issue regarding the underlying liability at the collection due process hearing. 2. Petitioner was offered a face-to-face hearing if he identified any relevant, nonfrivolous issues in writing or by calling as requested, but he did not do so. 3. Petitioner was offered the opportunity to discuss collection alternatives to the proposed levy action if he provided the requested financial information, but petitioner failed to submit the information. In addition, petitioner was not in compliance with his filing and payment obligations.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: March 27, 2008