- 4 -
Form 12153, Request for a Collection Due Process Hearing, in
which they challenged the validity of the assessments and
asserted that respondent failed to serve them with a valid notice
and demand for payment.
On June 4, 2001, respondent issued to the Mudds separate
Notices CP 504, “Urgent!! We [respondent] intend to levy on
certain assets. Please respond NOW”, for 1992 to 1997 and 1999,
informing them they owed taxes for those years and requesting
payment within 10 days. The Mudds failed to pay the amounts
owing.
On July 23, 2001, Appeals Officer Tom Conger conducted an
Appeals Office hearing that the Mudds attended. During the
hearing, petitioner acknowledged that Appeals Officer Conger
provided him with transcripts of account for the years in
question.2 Petitioner also acknowledged that he had filed tax
returns for the years in question reporting taxable income and
taxes due.
On November 21, 2001, respondent issued to the Mudds
separate Notices of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330. The notices stated that the
Appeals Office determined that it was appropriate to proceed with
collection for 1992 to 1997 and 1999. On January 7, 2002,
2 The record includes copies of transcripts of account for
the years in question dated June 14, 2001.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011