John W. Hauck, Jr. - Page 4




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          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.                      





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