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On September 11, 2000, petitioners filed with respondent
Form 12153, Request for a Collection Due Process Hearing. The
request included, inter alia, a challenge to the existence of
petitioners’ underlying tax liabilities for 1993 through 1997 on
the ground that petitioners were never provided with a valid
notice of deficiency or notice and demand for payment.
Petitioners also requested verification from the Secretary that
all applicable laws and administrative procedures were followed
with regard to the assessment and collection of the taxes in
dispute.
D. The Appeals Office Hearing
On January 30, 2001, petitioners attended an administrative
hearing conducted by Appeals Officer Donna Fisher. At the
hearing, the Appeals officer provided petitioners with Forms
4340, Certificates of Assessments, Payments, and Other Specified
Matters for the years 1993 through 1997. During the hearing,
petitioners requested that the Appeals officer identify the
statutory provisions establishing petitioners’ liability for
Federal income taxes and provide verification that all applicable
laws and administrative procedures were followed in the
assessment and collection process. Petitioners were informed
that the Forms 4340 provided to them were sufficient to satisfy
the verification requirement of section 6330(c)(1). The Appeals
officer terminated the hearing after petitioners declined to
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