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Background
On March 31, 2000, respondent mailed to petitioner a Final
Notice Of Intent To Levy and Notice Of Your Right To A Hearing
concerning petitioner’s unpaid income tax liabilities for the
years 1994 through 1997.2 On or about April 25, 2000, petitioner
filed with the Internal Revenue Service Office of Appeals
(Appeals Office) Form 12153, Request for a Collection Due
Process Hearing.
Petitioner attended the Appeals Office hearing in this
matter and argued that the assessments for the years in issue
were invalid inasmuch as the Appeals officer failed to produce
Forms 23-C, Assessment Certificate--Summary Record of
Assessments, for each year. Although the Appeals officer did not
provide petitioner with Forms 23-C for the years in issue, the
Appeals officer did provide petitioner with Forms 4340
(Certificates of Assessments and Payments) for each year.
On July 18, 2000, the Appeals Office issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 stating that respondent would proceed with collection
action for the years 1994 through 1997. On August 9, 2000,
petitioner filed with the Court a Petition For Levy Action Under
2 The Final Notice of Intent to Levy stated that petitioner
owed amounts from prior notices, interest, and additional
penalties for the years 1994, 1995, 1996, and 1997 totaling
$13,087.62, $840,848.30, $1,007,312.01, and $409,622.75,
respectively.
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Last modified: May 25, 2011