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petitioner attended. During the hearing, the Appeals officer
provided petitioner with a Form 4340, Certificate of Assessments,
Payments, and Other Specified Matters, with regard to his account
for 1997. A copy of the Form 4340, dated October 22, 2001, is
part of the record in this case.
On January 8, 2002, respondent issued to petitioner a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330. The notice stated that the Appeals Office
determined that it was appropriate to proceed with the collection
of petitioner’s outstanding tax liability for 1997. On February
5, 2002, petitioner filed with the Court a petition for lien or
levy action seeking review of respondent’s notice of
determination.2
As indicated, respondent filed a motion for summary judgment
asserting that there is no dispute as to a material fact and that
respondent is entitled to judgment as a matter of law. In
particular, respondent contends that, because petitioner
acknowledges that he received the notice of deficiency for 1997,
he cannot challenge the existence or amount of his underlying tax
liability for that year in this proceeding. Respondent further
asserts that the Appeals officer’s review of the transcript of
account for 1997 satisfied the verification requirement imposed
2 At the time that the petition was filed, petitioner
resided in Las Vegas, Nevada.
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