- 5 - On September 7, 2000, the Appeals officer issued petitioner a Notice of Determination Concerning Collection Action Under Section 6320 and/or 6330. Therein, the Appeals officer determined that the requirements of all applicable laws and administrative procedures were met. With respect to the issues raised by petitioner, the Appeals officer determined that: (1) The validity of the assessments of petitioner’s taxes for 1984 through 1987 need not be established by a Form 23C, but may instead be shown by means of a Form 4340; (2) that notices of deficiency were unnecessary with respect to the years in issue because petitioner had consented to assessment by executing Forms 4549;3 (3) that the Form 900 signed by petitioner was a valid extension of the period of limitations on collections; and (4) that petitioner’s transcript indicated the levy issued to his employer on March 18, 1997, was preceded by three notices. In addition, the Appeals officer determined that consideration of alternative means of collection was prevented by petitioner’s continued challenges to the validity of the assessments. The determination concluded that enforced collection was appropriate. On October 7, 2000, petitioner filed suit in the U.S. District Court for the Western District of Texas, El Paso 3 The Appeals officer examined Forms 4549 executed by petitioner for 1984 and 1985 and, while not retrieving such forms for 1986 and 1987, noted that the latter 2 years involved the same adjustment to filing status as the earlier years and were audited and closed at the same time.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011