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assessed the determined deficiencies and additions to tax for
1991, 1992, and 1993, as well as statutory interest. On that
same day, respondent sent petitioner notices of balance due,
informing petitioner that she had liabilities for 1991, 1992, and
1993, and requesting that she pay them. Petitioner failed to do
so.
D. Respondent’s Final Notice and Petitioner’s Response
On October 25, 1999, respondent sent petitioner a Final
Notice-–Notice of Intent to Levy and Notice of Your Right to a
Hearing (the Final Notice). The Final Notice was issued in
respect of petitioner’s outstanding liabilities for 1990 through
1993.
On November 23, 1999, petitioner submitted to respondent
Form 12153, Request for a Collection Due Process Hearing.
Petitioner’s request stated in pertinent part: “The basis of my
complaint is what I believe to be the lack of a valid summary
record of assessment pursuant to 26 CFR �301.6203-1.”
E. The Administrative Hearing
On June 22, 2000, Veronica Lindersmith of respondent’s
Appeals Office in Las Vegas, Nevada, conducted an administrative
hearing by way of a telephone conference with petitioner’s
representative, Thomas W. Roberts.2 By letter dated August 8,
2 The conference was conducted by telephone in order to
accommodate Mr. Roberts, whose office was located out of state.
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