Ronald A. Davis - Page 1

                                   115 T.C. No. 4                                     

                               UNITED STATES TAX COURT                                

                           RONALD A. DAVIS, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13532-99L.                   Filed July 31, 2000.           

                    Pursuant to sec. 6330(a), I.R.C., R issued a                      
               notice of intent to levy to P indicating that R                        
               intended to collect income taxes due for the taxable                   
               years 1991, 1992, and 1993.  Pursuant to sec. 6330(b),                 
               I.R.C., P requested a hearing before IRS Appeals                       
               regarding the proposed collection action.  Ultimately,                 
               Appeals issued a notice of determination to P stating                  
               that all applicable laws and administrative procedures                 
               had been met and that collection would proceed.                        
                    Pursuant to sec. 6330(d), I.R.C., P filed a timely                
               petition for review with this Court.  P contests the                   
               Appeals determination on the grounds that:  (1) The                    
               Appeals officer who conducted the hearing failed to                    
               properly verify that the requirements of any applicable                
               law or administrative procedure had been met as                        
               required by sec. 6330(c)(1), I.R.C., because the                       
               Appeals officer relied on Form 4340, Certificate of                    
               Assessments and Payments, to verify the assessments of                 
               taxes in issue; (2) P was not afforded the type of                     

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