- 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 filingPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011