-4-
On December 7, 2000, respondent mailed to petitioners a
“Final Notice - Notice of Intent to Levy and Notice of Your Right
to a Hearing” (final notice). The final notice informed
petitioners of (1) respondent’s intention to levy under section
6331 and (2) petitioners’ right under section 6330 to a hearing
with respondent’s Office of Appeals (Appeals). Enclosed with the
final notice was a copy of Form 12153, Request for a Collection
Due Process Hearing.
On December 11, 2000, petitioners sent to respondent the
Form 12153 requesting the referenced hearing. Petitioners
attached to the Form a request that the hearing officer have at
the hearing “the specific Code Section making me [petitioners]
‘liable to pay’ the taxes at issue,” “verification that the
requirements of any applicable law or administrative procedure
have been met,” and “Delegation Order from the Secretary
delegating to that person [director of the service center] the
authority to prepare such a verification.”
On June 28, 2001, Appeals Officer Wayne McClellan held with
petitioners a hearing under section 6330. At the hearing, the
Appeals officer provided petitioners with a Form 4340,
Certificate of Assessments, Payments and Other Specified Matters.
The Form 4340 was dated May 16, 2001, and was for 1998.
On August 16, 2001, respondent issued to petitioners
duplicate Notices of Determination Concerning Collection
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Last modified: May 25, 2011