- 5 - 6330 hearing. In particular, petitioner argues that he was not afforded a “fair hearing” because he did not receive a Form 4340, Certificate of Assessments and Payments, and was deprived of his right to subpoena documents and witnesses and confront witnesses. In regard to the 1996 tax liability, respondent argues that petitioner’s contentions that he did not receive a “fair” hearing are either irrelevant or refuted by the transcript of petitioner’s account. As explained later in this opinion, we conclude that there was no abuse of discretion. A. Verification of Petitioner’s Account Petitioner contends that he was not shown a Form 4340 at his hearing before Appeals. We note that petitioner also contended that he did not receive a statutory notice of deficiency. Upon further inquiry at trial, however, it became apparent that he had received a notice of deficiency.3 Accordingly, we approach with caution petitioner’s contention that he was not shown a Form 4340. 3 PETITIONER: There is no evidence of a notice of deficiency being issued. * * * THE COURT: Well, did you receive a notice of deficiency? PETITIONER: I received something that told me it was a 90-day letter. THE COURT: That is a notice of deficiency.Page: Previous 1 2 3 4 5 6 7 8 Next
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