Stanley Howard - Page 3




                                        - 3 -                                         
               On April 26, 2000, respondent provided written notification            
          to petitioner’s representative that a telephone hearing was                 
          scheduled for June 6, 2000, and enclosed copies of respondent’s             
          computer transcripts of account for each of the tax years at                
          issue.  The Appeals officer relied upon the computer transcripts            
          of account (a.k.a. MEFTRA or MEFTRA-X) that were contained in the           
          administrative file as both proof that a valid assessment was               
          made and verification of petitioner’s liability.                            
               At the time scheduled for the hearing, the Appeals officer             
          placed telephone calls to petitioner’s representative at two                
          different telephone numbers provided by the representative.                 
          Petitioner’s representative was not available at either number.             
          The Appeals officer left messages at both numbers requesting that           
          petitioner’s representative contact the Appeals officer to                  
          reschedule the hearing.  Petitioner’s representative did not                
          return either message.                                                      
               On June 14, 2000, respondent sent to petitioner a “NOTICE              
          OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION              
          6320 AND/OR 6330” (notice of determination).  The notice of                 
          determination states in pertinent part:                                     
                    You allege the assessments and the                                
                    liabilities are invalid.  Statutory Notice of                     
                    Deficiency (SND) were sent to you dated March                     
                    28, 1997 for the 1992 tax year, and October                       
                    24, 1997 for the 1993, 1994 and 1995 tax                          
                    years.  There is no evidence that you                             
                    responded to the SNDs either by filing                            






Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011