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D. The Appeals Office Hearing
On November 16, 2001, Appeals Officer Julie Peterson
conducted an Appeals Office hearing that petitioners attended.
During the hearing, the Appeals officer provided petitioners with
a Form 4340, Certificate of Assessments, Payments, and Other
Specified Matters, regarding their account for the taxable year
1998. According to a purported transcript of the hearing
prepared by petitioners, petitioners declined to discuss
collection alternatives. Rather, petitioners stated that they
wished to challenge their underlying tax liability.
E. Respondent’s Notice of Determination
On January 3, 2002, respondent sent petitioners a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330. The notice stated that the Appeals Office had
determined that the lien filing was appropriate.
F. Petitioners’ Petition
On February 5, 2002, petitioners filed with the Court a
petition for lien or levy action seeking review of respondent’s
notice of determination.2 The petition includes allegations
that: (1) The Appeals officer failed to obtain verification from
the Secretary that the requirements of any applicable law or
2 At the time that the petition was filed, petitioners
resided in Las Vegas, Nevada. The envelope bearing the petition
contains a timely U.S. Postal Service postmark dated Jan. 31,
2002. See secs. 6330(d)(1), 7502.
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Last modified: May 25, 2011