John Thurman and Elaine Sheryl Horejs - Page 6




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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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