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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 a
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