-4-
Before May 9, 2003, Appeals Officer Johnson provided
petitioners with a Form 4340, Certificate of Assessments,
Payments, and Other Specified Matters. The Form 4340 certified a
deficiency of $312,721 and a section 6662 accuracy-related
penalty of $62,544.20. The Form 4340 certified that respondent
assessed the foregoing amounts and issued a “statutory notice of
balance due” on February 7, 2000. The Form 4340 further
certified that respondent subsequently issued a “notice of
balance due” and a “statutory notice of intent to levy”.
Respondent’s Supervisory Investigative Analyst Lee Hansen signed
the Form 4340 on March 19, 2003.
Appeals Officer Johnson issued a letter dated May 9, 2003,
as part of petitioners’ section 6330 hearing by correspondence.
The letter stated that (1) the underlying tax liability could not
be challenged because petitioners had received a statutory notice
of deficiency and had had an opportunity to dispute the
underlying tax liability; (2) issues included the appropriateness
of collection actions, offers of collection alternatives, and
1(...continued)
• We have received no assessment certificate to date
which includes our individual assessment.
• We have received no Notice and Demand.
• IRS computer records show some other party is
using our Social Security number, so that NONE of
the entries on our records can be relied upon as
correct.
• There are numerous errors in our Individual Master
File.
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Last modified: May 25, 2011