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4340, Certificate Of Assessments, Payments, And Other Specified
Matters, certified transcripts which detailed the assessment of
the income tax deficiencies and accuracy-related penalties with
respect to petitioner’s 1996 and 1997 taxable years. Forms 4340
were also provided to petitioner with respect to the frivolous
return penalties assessed for each of his taxable years at issue.
The Appeals officer terminated the hearing after petitioner
declined to discuss any collection alternatives.
On January 25, 2001, respondent’s Appeals Office sent
petitioner two separate “NOTICES OF DETERMINATION CONCERNING
COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330" stating
respondent’s intention to proceed with collection with respect to
petitioner’s 1996 and 1997 taxable years. One notice of
determination related to the income taxes and accuracy-related
penalties assessed against petitioner and informed him that he
would have 30 days to contest the determination by filing a
petition with the Tax Court. The notice of determination
included findings that all applicable statutory and
administrative procedures were met, that petitioner failed to
present any collection alternatives, and that the proposed lien
was appropriate.
The other notice of determination related to the frivolous
return penalty assessments and informed petitioner that he would
have 30 days to contest the determination by filing a petition
with the appropriate United States District Court.
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Last modified: May 25, 2011