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Background
On June 16 and July 16, 1997, respondent issued notices of
deficiency relating to Vernice Kuglin’s 1994 and 1995 Federal
income taxes, respectively, but petitioner did not seek
redetermination of the deficiencies.
On December 4, 1997, petitioner’s counsel requested a copy
of the assessments relating to petitioner’s 1994 and 1995 income
taxes. On June 28, 1999, respondent issued a Notice of Intent to
Levy and Notice of Your Right to a Hearing. On July 15, 1999,
petitioner filed a Request for a Collection Due Process Hearing
(i.e., Form 12153) and contended that there was no “valid summary
record of assessment”. On September 16, 1999, respondent’s
Appeals officer printed out computer transcripts (transcripts) of
respondent’s records. The transcripts contained petitioner’s
Social Security number and the first four letters of her last
name; monetary figures representing amounts assessed, identified
by respondent’s transaction codes; and petitioner’s adjusted
gross and taxable income. In a letter dated December 13, 1999,
the Appeals officer responded to petitioner’s request for a
hearing and scheduled a telephone hearing, which was held on
January 25, 2000.
On February 16, 2000, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (determination), sustaining the proposed collection
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Last modified: May 25, 2011