-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 CollectionPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011