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 ofPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011