- 6 - 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.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011