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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.
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