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respondent alleged were owed. On or about February 20, 2001,
petitioners responded to Letter 3172 by filing another Form
12153. Petitioners listed in that form that their address was
the Hartnell address. Petitioners requested from respondent in
both forms that he provide them with: (1) A copy of the record
of assessment, (2) a copy of any record of any proceeding as to
the notice of assessment, and (3) a copy of any record of any
proceeding or administrative act, upon which respondent had
relied to determine that petitioners were liable taxpayers.
Before the instant judicial proceeding was commenced, respondent
did not provide petitioners with any of the requested
information. During this proceeding, respondent provided
petitioners with the relevant Form 4340, Certificate of
Assessments, Payments, and Other Specified Matter.
On May 22, 2001, the Internal Revenue Service Office of
Appeals held the requisite hearing with Mr. Carey under sections
6320 and 6330. During the hearing, Mr. Carey requested a copy of
the notice of deficiency. The Appeals officer did not give Mr.
Carey a copy of the notice of deficiency and did not allow Mr.
Carey to discuss either the notice of deficiency or the
deficiency itself.
On June 8, 2001, respondent issued to petitioners a Notice
of Determination Concerning Collection Action(s) under Section
6320 and/or 6330. Subsequently, in August 2001, petitioners
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