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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.
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