-4-
demand pursuant to 26 USC 6203 and Trea. Reg. 301-6203-
1) Include a copy of the Accounting Assessment Journal
(assessment list) and other supporting documents as
required by IR Code section 6203 and Reg. 301-6203-1.
3. Provide me with the record of any proceeding
of Notice of Assessment which may have been issued to
me showing the dates of assessment and the date of said
notices and all records which provide proof that theses
[sic] required notice were mailed.
4. Provide me with the record of any proceeding
or administrative act, upon which the agency has relied
upon to determine that I am in fact a liable taxpayer
for the above years. Alternatively, I demanded that
you provide a hearing so that it may be determined,
based upon necessary facts, whether or not I am or was
liable for taxes alleged that year.
* * * * * * *
In accordance with IRC Section 6320(c)(1), we request
that the appeals officer at the hearing obtain
verification from the secretary that requirements of
any applicable law or administration procedure have
been met. We will expect the Secretary to provide us
with evidence that Internal revenue Regulation (IR
Regs.) 301.6203-1 has been complied with.
In accordance with IRC Section 6230(c)(2)(A), we feel
is [sic] very relevant that the IRS can provide no
evidence that a procedurally correct lawful assessment
exist for any of the tax periods * * * therefore, under
IRC Section (c)(2)(B), we will raise at the hearing
challenges to the existence and amount of the
Underlying Tax Liability, Unless the Secretary can
provide evidence that a procedural correct lawful
assessment, certified by and assessment officer, is in
existence * * *
No hearing was held with petitioners. Instead, on the basis
of petitioners’ letter and attached document, Appeals issued to
petitioners on July 6, 2001, a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 for 1996.
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