- 10 -
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
occurred:
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
issue.
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
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011