Janet N. Moore - Page 3




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            3406 and 3509) for the periods ending March 31, 1994, and June                             
            30, 1995.  Respondent subsequently determined that petitioner was                          
            liable for a penalty pursuant to section 6672 equal to the unpaid                          
            taxes.1                                                                                    
                  Respondent subsequently initiated a collection action                                
            against petitioner.  On September 2, 1999, respondent's Boston                             
            Appeals Office issued a notice of determination to petitioner                              
            stating in pertinent part:                                                                 
                  We have reviewed the proposed collection action for the                              
                  periods [May 31, 1994 and June 30, 1995].  This letter                               
                  is your legal Notice of Determination, as required by                                
                  law. * * *                                                                           
                  If you want to dispute this determination in court, you                              
                  have 30 days from the date of this letter to file a                                  
                  complaint in the appropriate United States District                                  
                  Court for a redetermination.                                                         
                  *        *        *        *       *        *        *                               
                  Summary of Determination:                                                            
                  1. It has been determined that all requirements of                                   
                  administrative procedure and applicable law have been                                
                  met with regards to the proposed collection action.                                  


                  1  Sec. 6672(a) provides in pertinent part:                                          
                        SEC. 6672(a).  General Rule.-–Any person required                              
                  to collect, truthfully account for, and pay over any                                 
                  tax imposed by this title who willfully fails to                                     
                  collect such tax, or truthfully account for and pay                                  
                  over such tax, or willfully attempts in any manner to                                
                  evade or defeat any such tax or the payment thereof,                                 
                  shall, in addition to other penalties provided by law,                               
                  be liable to a penalty equal to the total amount of the                              
                  tax evaded, or not collected, or not accounted for and                               
                  paid over. *  *  *                                                                   





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