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a Hearing that was identical to the final notice issued to her
husband.
On or about March 23, 1999, petitioners filed with
respondent a Form 12153, Request for a Collection Due Process
Hearing, in which they challenged the proposed collection action
on the ground that there was no valid summary record of
assessment.
On December 21, 1999, Settlement Officer Sherwin Cogan wrote
a letter to petitioners outlining the collection review process
and enclosing transcripts of account taken from respondent’s
Integrated Data Retrieval System (IDRS transcripts of account).
The IDRS transcripts of account listed by date and amount the
assessments made against petitioners for the taxable years 1989
through 1993.
On May 11, 2000, Settlement Officer Carl Carter conducted an
Appeals Office hearing with petitioners’ representative, Thomas
W. Roberts. During the hearing, Settlement Officer Carter
incorrectly stated that petitioners had executed agreements
during the examination process conceding adjustments to their tax
liabilities for the each of the years in dispute. Settlement
Officer Carter declined to provide Mr. Roberts with copies of any
such agreements during the Appeals Office hearing. However, on
May 15, 2000, Settlement Officer Carter wrote to Mr. Roberts and
provided him with a copy of the Form 4549 that petitioners
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Last modified: May 25, 2011