Stephen and Patricia Lindsey - Page 6




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          proceed with collection against petitioners for the taxable years           
          1989 through 1993.  Petitioners filed with the Court a timely               
          Petition for Lien or Levy Action Under Code Section 6320(c) or              
          6330(d) challenging respondent’s notice of determination.3  The             
          petition includes allegations that respondent erred by failing              
          to:  (1) Obtain verification from the Secretary that the                    
          requirements of any applicable law or administrative procedure              
          were met as required under section 6330(c)(1); and (2) identify             
          the assessment officer that prepared the Forms 23C, Summary                 
          Record of Assessment, for the years in issue.                               
               After respondent filed an answer to the petition, respondent           
          filed a Motion for Summary Judgment and Declaration, attaching              
          thereto Forms 4340, Certificate of Assessments, Payments, and               
          Other Specified Matters, for each of the years in issue.                    
          Petitioners filed a response to respondent’s motion.  Petitioners           
          assert that material issues of fact remain in dispute regarding             
          the documents that Settlement Officer Carter relied on at the               
          Appeals Office hearing to verify that the requirements of all               
          applicable laws and administrative procedures were met with                 
          regard to the disputed assessments.                                         
               This matter was called for hearing at the Court's motions              
          sessions held in Washington, D.C., on November 14, 2001, December           

               3  At the time that the petition was filed, petitioners                
          resided in Garden Grove, California.                                        






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