Ginger Harmornick - Page 6

                                        - 6 -                                         
          2000, the Appeals officer provided Mr. Roberts with copies of               
          Forms 4340 (Certificate of Assessments, Payments, and Other                 
          Specified Matters) for each of the years 1990, 1991, 1992, and              
          1993.  Copies of the Forms 4340 are attached to respondent’s                
          motion for summary judgment, which was served on petitioner.                
               F.  Respondent’s Notice of Determination                               
               On August 28, 2000, respondent sent petitioner a Notice of             
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330.  The notice stated that the Appeals Office had                 
          determined that it was appropriate for respondent to proceed with           
          the collection of petitioner’s outstanding tax liabilities for              
          1990 through 1993.                                                          
               G.  Petitioner’s Petition                                              
               On September 29, 2000, petitioner filed with the Court a               
          petition for lien or levy action seeking review of respondent’s             
          notice of determination.3  The petition includes allegations                
          that: (1) The Appeals officer failed to obtain proper                       
          verification from the Secretary that the requirements of all                
          applicable laws and administrative procedures were met as                   
          required by section 6330(c)(1); and (2) the Appeals officer                 
          failed to provide petitioner with requested documents such as a             
          summary record of assessment.                                               

               3  At the time that the petition was filed, petitioner                 
          resided in Henderson, Nevada.                                               

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011