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Roberts to represent petitioner for his 1980 through 1999 tax
years.
On April 26, 1999, Revenue Officer Henry Morrison mailed
petitioner and Mr. Roberts a copy of the Summary Record of
Assessments, RACS Report (RACS report), for September 21, 1998,
an explanation of the RACS report by Disclosure Officer Michael
Ormond, petitioner’s Individual Master File Tax Module for 1995
and 1996, and petitioner’s literal transcript for 1995 and 1996.
These tax modules listed the assessment date for 1995 and 1996 as
September 21, 1998.
On June 28, 1999, respondent mailed petitioner a Final
Notice, Notice of Intent to Levy and Notice of Your Right to a
Hearing, Form 1058, for 1995 and 1996. Petitioner timely
requested a hearing. The only issues raised in petitioner’s
request for a hearing were the lack of a valid summary record of
assessment and the validity of the assessment.
Appeals Officer Diane Villa mailed petitioner and his
representatives a letter scheduling a hearing for July 27, 2000.
On July 12, 2000, petitioner’s representative called respondent
and requested that the hearing be held via the telephone.
On July 27, 2000, Ms. Villa held a hearing via telephone
with Mr. Roberts. Petitioner attempted to have a court reporter
present at the hearing and wanted the opportunity to cross-
examine witnesses. Respondent denied petitioner’s request to
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Last modified: May 25, 2011