Jose A. Perez - Page 7

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          assessments); (2) respondent had given petitioner notice of the             
          return assessments as required by section 6303; (3) that notices            
          of deficiency were not required with respect to the return                  
          assessments for 1984 through 1987 because the assessments covered           
          amounts reported as due on petitioner’s returns; and (4) that the           
          Form 900 executed by petitioner was valid, extending the period             
          of limitations for collection for the years 1984 through 1987 to            
          December 31, 2000.                                                          
               In his petition in the instant case, petitioner asserts:               
          (1) That the proposed collection is time-barred; (2) that                   
          respondent failed to properly assess his tax liabilities or                 
          notify him of the assessments for the years 1984 through 1987;              
          (3) that he did not receive notices of deficiency for the years             
          in issue; and (4) that respondent failed to conduct a fair                  
          hearing (a) by refusing to explain how the proposed levy was                
          balanced with petitioner’s interests; (b) by directing the                  
          Appeals officer not to address the “23C Summary Record of                   
          Assessment” issue, (c) by refusing to grant a hearing to                    
          petitioner’s spouse; and (d) by refusing to explain why Form 4340           
          was given “evidentiary precedence” over petitioner’s individual             
          master file.                                                                
               Section 6331(a) provides that if any person liable to pay              
          any tax neglects or refuses to pay such tax within 10 days after            

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Last modified: May 25, 2011