- 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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