- 4 - redetermination with the Court contesting the notice of deficiency. On July 23, 2000, respondent mailed to petitioners a Final Notice of Intent to Levy and Notice of Your Right to a Hearing that stated petitioners owed taxes and statutory additions for 1996 totaling $37,614.14 and that respondent was preparing to collect the amount due by levy. On August 16, 2000, petitioners filed with respondent a Request for a Collection Due Process Hearing that included a request that respondent provide petitioners with a summary record of assessment, and verification that all applicable laws and administrative procedures were met with regard to the assessment and proposed collection for 1996. On July 10, 2001, Appeals Officer Eugene Chu conducted an administrative hearing in petitioners’ case by way of a telephone conference call with petitioner Robert Hale and his representative, Brian Malatesta. Prior to the hearing, Appeals Officer Chu provided petitioners with a Form 4340, Certificate of Assessments, Payments, and Other Specified Matters, which showed that, for 1996, respondent entered assessments against petitioners for: (1) The amounts determined to be due in the notice of deficiency dated May 19, 1998; and (2) statutory interest. During the hearing, Mr. Malatesta challenged the assessments entered against petitioners on the ground that aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011