Jeffrey S. and Susan L. Duffield - Page 3

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          representing amounts assessed, identified by respondent’s                   
          transaction codes; and petitioners’ adjusted gross and taxable              
               On March 16, 2000, respondent issued a Notice of                       
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 (determination), sustaining the proposed collection             
          action.  In making the determination, respondent relied on the              
          transcripts to verify the assessments.  Respondent, prior to                
          making his determination, did not give petitioners copies of                
          these transcripts or Forms 4340, Certificates of Assessments,               
          Payments, and Other Specified Matters (Forms 4340).  On December            
          22, 2000, respondent’s counsel provided petitioners with a copy             
          of the transcripts.  At trial, on January 8, 2001, respondent               
          provided petitioner, and introduced into the record, Forms 4340.            
          Respondent also requested that the Court impose a section                   
          6673(a)(1) penalty.                                                         
               Section 6330(b)(1) provides that if a taxpayer requests a              
          hearing, “such hearing shall be held by the Internal Revenue                
          Service Office of Appeals.”  Section 6330(c)(1) states:  “The               
          appeals officer shall at the hearing obtain verification from the           
          Secretary that the requirements of any applicable law or                    
          administrative procedure have been met.”  Section 6330(c)(2)(B)             
          allows challenges to the existence or amount of the underlying              

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