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The transcripts indicated that respondent made assessments
against petitioner on February 14, 2000, for the taxes and
additions to tax set forth in the notice of deficiency dated
September 21, 1999, and for statutory interest. In addition, the
transcripts of account indicated that on February 14, 2000,
respondent issued to petitioner notices and demand for payment of
the assessed amounts.
On May 9, 2001, respondent issued to petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330. The notice states that the Appeals Office
determined that it was appropriate to proceed with the collection
of petitioner’s outstanding tax liabilities by levy. On May 17,
2001, petitioner filed with the Court an imperfect petition for
lien or levy action seeking review of respondent’s notice of
determination.3 On June 19, 2001, petitioner filed an amended
petition alleging that the Appeals officer failed to obtain
verification from the Secretary that the requirements of any
applicable law or administrative procedure were met as required
under section 6330(c)(1).
2(...continued)
code that is entered into respondent’s integrated data retrieval
system (IDRS) to obtain the transcript. IDRS is essentially the
interface between respondent’s employees and respondent’s various
computer systems.
3 At the time that the petition was filed, petitioner
resided in Mission, Kansas.
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