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The issue for decision is whether respondent abused his
discretion in relying upon transcripts of account to verify
assessment of petitioner’s tax liabilities for purposes of
section 6330(c)(1).
Background
At the time the petition was filed, petitioner resided in
Portland, Texas.
On August 29, 2000, respondent filed a Notice of Federal Tax
Lien (lien filing) against petitioner relating to petitioner’s
assessed and unpaid Federal income taxes for 1992 and 1993.
On September 20, 2000, petitioner timely submitted to
respondent’s Appeals Office a written request for a collection
hearing under section 6320 to challenge respondent’s lien filing.
In petitioner’s written request, petitioner did not identify any
specific issues or the basis for any specific challenges to
respondent’s lien filing.
On January 11 and 31, 2001, respondent’s Appeals Office
mailed letters to petitioner inviting petitioner to meet
personally with respondent’s Appeals officer, and respondent
enclosed with those letters copies of petitioner’s transcripts of
account for 1992 and 1993 (Form MEFTRA) and a “plain language”
computer printout of petitioner’s account for 1992 and 1993 (the
individual master file (IMF)).
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