Anthony M. Davich - Page 10

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          verification that all applicable laws and administrative                    
          procedures had been followed in the assessment and collection               
          process.  Petitioner was informed that the transcripts previously           
          provided were sufficient to satisfy the verification requirement            
          of section 6330(c)(1).  Petitioner also alleged that he never               
          received “the statutory notice and demand for payment”.  In                 
          response to the Appeals officer’s question whether petitioner               
          wished to discuss collection alternative, the following colloquy            
                    APPEALS OFFICER:  * * * Do you want to discuss                    
               collection alternatives?                                               
                    PETITIONER:  Yes.  I’ll pay the amount you want                   
               right now.                                                             
                    APPEALS OFFICER:  Okay, by check?  Are you going                  
               to pay me with a check?                                                
                    PETITIONER:  Yep.  You just cite for me the                       
               regulation and statute that requires me to pay it [the                 
               outstanding liabilities].                                              
                              *   *   *   *   *   *   *                               
                    PETITIONER:  Let the record show I’m willing to                   
               pay the amount that’s at issue right now, if Mr. Sigler                
               [the Appeals officer] would just point out the statute                 
               and regulation that requires me to pay the tax at                      
               F.  Respondent’s Notice of Determination                               
               On September 21, 2001, respondent’s Appeals Office issued              
          to petitioner a Notice of Determination Concerning Collection               
          Action(s) Under Section 6320 and/or 6330 with regard to his tax             
          liabilities for 1997 and 1998.  In the notice, the Appeals Office           

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