- 4 - have a court reporter and cross-examine witnesses at the hearing.2 The only issues petitioner raised at the hearing were the validity of the assessment for 1995 and 1996 and an issue regarding a levy.3 The issue regarding the levy was resolved at the hearing as no levy had taken place. During the hearing, Mr. Roberts acknowledged that petitioner had received the RACS report and petitioner’s transcripts of account for 1995 and 1996. Ms. Villa reviewed the transcripts of account provided to petitioner by Mr. Morrison and then-current transcripts of account for 1995 and 1996 to verify the name of petitioner, the tax periods, the type of tax, the date of the assessments, and the amount of the assessments. In verifying the accuracy of the assessments, Ms. Villa compared the amounts determined in the notices of deficiency for 1995 and 1996 with the amounts assessed on petitioner’s transcripts of account. These numbers matched. On August 29, 2000, respondent mailed petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, for 1995 and 1996 determining to proceed with collection. 2 Respondent, however, allowed Mr. Roberts to tape record the hearing. 3 During the hearing, petitioner did not raise the underlying tax liabilities, any collection alternatives, or the appropriateness of the proposed collection activities, nor did he identify any irregularities in the assessment process.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011