Gene and Ciao Newman - Page 9




                                        - 9 -                                         
               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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