Johnnie Ann Holliday - Page 3




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               After the hearing and before the date of the notice of                 
          determination, the Appeals officer sent to petitioner a                     
          “MFTRA-X”.  The Appeals officer testified at trial:                         
                    Q   [By respondent’s counsel]   And explain to me                 
               what the difference between a MFTRA-X is and the tax                   
               * * * [module] that you’ve already testified you looked                
               at.                                                                    
                    A   [By Appeals officer]   The MFTRA-X is a user-                 
               friendly transcript of the taxpayer’s account.  It is                  
               in plain English.  It’s in understandable terms,                       
               whereas the tax module is not.                                         
                    Q   Does it contain--what kind of information does                
               it contain?                                                            
                    A   The MFTRA-X contains the taxpayer’s name, the                 
               taxpayer’s identification number, the type of tax that                 
               is owed, the date of the assessment, and the amount of                 
               the assessment.                                                        
                    Q   Why did you mail those to the taxpayers                       
               opposed to the 4340s?                                                  
                    A   Well, the MFTRA-X and the 4340, they’re both                  
               obtained from IDRS, and the MFTRA-X is retrievable                     
               faster than a 4340, and I also figured that because it                 
               obtained [sic] the same information, I would forward                   
               the MFTRA-X to the taxpayers.                                          
                    Q   Did you forward that to her prior to the date                 
               that the notice of determination was issued in this                    
               case?                                                                  
                    A   Yes, I did.                                                   
                    Q   Can you explain to the Court what is the                      
               difference between a MFTRA-X and a Form 4340?                          
                    A   There’s relatively little difference.  The                    
               major difference is that the 4340 is certified by the                  
               IRS, whereas the MFTRA-X is not.                                       








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