- 3 - Between January 24 and May 7, 2001, petitioner, petitioner's spouse, and petitioner’s legal representative exchanged a number of letters with respondent’s Appeals officer in which petitioner explained that petitioner would only be satisfied if respondent provided to petitioner not the above transcripts of account but specifically “Forms 23C, Summary Record of Assessments” relating to petitioner’s Federal income taxes for 1992 and 1993. In his letters, respondent’s Appeals officer made it clear that respondent was relying on the above referenced transcripts of account, not “Forms 23C”, to verify the assessments that were the bases for the lien filing, and that respondent was willing to meet face-to-face with petitioner and petitioner’s spouse and representative and to make available to petitioner additional copies of those transcripts. Respondent’s letters also suggested specific dates for a face-to-face meeting, but petitioner and petitioner’s representative refused to meet with respondent’s Appeals officer unless a commitment was made by the Appeals officer to obtain and to have at the meeting a copy of “Forms 23C” relating to petitioner’s 1992 and 1993 Federal income taxes. On May 17, 2001, respondent’s Appeals Office mailed to petitioner’s representative a notice of determination in which it was explained that the above lien filing made by respondent withPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011