- 6 - proceed with collection against petitioners for the taxable years 1989 through 1993. Petitioners filed with the Court a timely Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d) challenging respondent’s notice of determination.3 The petition includes allegations that respondent erred by failing to: (1) Obtain verification from the Secretary that the requirements of any applicable law or administrative procedure were met as required under section 6330(c)(1); and (2) identify the assessment officer that prepared the Forms 23C, Summary Record of Assessment, for the years in issue. After respondent filed an answer to the petition, respondent filed a Motion for Summary Judgment and Declaration, attaching thereto Forms 4340, Certificate of Assessments, Payments, and Other Specified Matters, for each of the years in issue. Petitioners filed a response to respondent’s motion. Petitioners assert that material issues of fact remain in dispute regarding the documents that Settlement Officer Carter relied on at the Appeals Office hearing to verify that the requirements of all applicable laws and administrative procedures were met with regard to the disputed assessments. This matter was called for hearing at the Court's motions sessions held in Washington, D.C., on November 14, 2001, December 3 At the time that the petition was filed, petitioners resided in Garden Grove, California.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011