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