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permitted to offer documentation to the Appeals Office
challenging the amount of the wage income attributed to her in
the notices of deficiency.
In early February 2001, Appeals Officer Johnson conducted an
administrative hearing in petitioner’s case. By letter to
petitioner dated February 22, 2001, Appeals Officer Johnson
provided petitioner with “certificates of official record”, i.e.,
Forms 4340, Certificate of Assessments, Payments, and Other
Specified Matters, dated February 2, 2001, and informed
petitioner that she should immediately submit any additional
information regarding her case. Petitioner did not provide the
Appeals Office with any additional information.
The Forms 4340 show that, on August 9, 1999, respondent
entered assessments against petitioner for taxes and additions to
taxes set forth in the notices of deficiency for 1995 and 1996,
and statutory interest and penalties for failure to pay the
taxes. In addition, on August 9, September 13, and October 18,
1999, respondent issued to petitioner Notices of Balance Due for
1995 and 1996.
On April 26, 2001, the Appeals Office issued to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 stating that respondent would proceed
with collection against petitioner for 1995 and 1996. The notice
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Last modified: May 25, 2011