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6320 in respect of their outstanding liabilities for 1992, 1993,
and 1994. On May 13, 2000, petitioners submitted to respondent
a Form 12153, Request for a Collection Due Process Hearing,
challenging respondent’s Notice of Federal Tax Lien Filing.
Petitioners’ request stated that “there is no valid assessment
against us.”
F. The Appeals Office Hearing
On March 23, 2001, Appeals Officer Angela M. Carmouche
(the Appeals officer) conducted an Appeals Office hearing that
petitioners attended. By letter dated April 23, 2001, the
Appeals Office forwarded to petitioners Forms 4340, Certificate
of Assessments, Payments, and Other Specified Matters, with
regard to their taxable years 1992, 1993, and 1994. Copies of
the Forms 4340, dated March 27, 2001, are attached to
respondent’s Motion for Summary Judgment, which was served on
petitioners. The Appeals Office also provided petitioners with a
copy of the Court’s opinion in Pierson v. Commissioner, 115 T.C.
576 (2000).
G. Respondent’s Notice of Determination
On July 2, 2001, respondent sent petitioners 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 “should not restrict the appropriate
collection action.”
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