Clyde E. Hack and Carole J. Hack - Page 4




                                         -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                    






Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011