William B. Meyer - Page 3




                                                - 3 -                                                  
            Background                                                                                 
                  On October 19, 1998, respondent issued a collection letter                           
            to William B. and Diane S. Meyer (petitioners) requesting that                             
            they pay frivolous return penalties under section 6702 in the                              
            amount of $500 for each of the taxable years 1996 and 1997.  On                            
            February 25, 1999, respondent issued to petitioners separate                               
            final notices of intent to levy for the years 1996 and 1997.                               
                  Petitioners timely requested a hearing with the Internal                             
            Revenue Service Office of Appeals (Appeals Office) pursuant to                             
            section 6330(a).  However, the appeals officer assigned to                                 
            petitioners' case did not offer or schedule a hearing because his                          
            communications with petitioners led him to believe that they were                          
            challenging respondent's collection efforts solely on                                      
            constitutional grounds.                                                                    
            On January 13, 2000, the Appeals Office issued to                                          
            petitioners separate Notices of Determination Concerning                                   
            Collection Action(s) Under Section 6320 and/or 6330                                        
            (determination letters) stating that all applicable laws and                               
            administrative procedures had been met and that respondent would                           
            proceed with collection against them for 1996 and 1997.                                    
                  On or about February 4, 2000, petitioners wrote to the                               
            Appeals Office to complain that they had not received a hearing                            
            prior to the issuance of the above-described determination                                 
            letters.  On February 9, 2000, Appeals Officer Tony Aguiar wrote                           






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011