Harvey Doyne Perry, Jr. - Page 8

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          underlying tax liability for 1997, as well as allegations that              
          petitioner was never provided with a valid notice of deficiency             
          or notice and demand for payment and that the Appeals officer had           
          failed “to identify the statute that makes me ‘liable to pay’ the           
          taxes at issue”.  Petitioner also requested verification from the           
          Secretary that all applicable laws and administrative procedures            
          were followed with regard to the assessment and collection of the           
          tax liability in question.                                                  
               D.  The Appeals Office Hearing                                         
               On July 26, 2001, petitioner attended an administrative                
          hearing in Las Vegas, Nevada conducted by Appeals Officer Douglas           
          DeSoto (the Appeals officer).  Prior to the hearing, the Appeals            
          officer obtained and reviewed Form 4340, Certificate of                     
          Assessments, Payments, and Other Specified Matters, pertaining to           
          petitioner’s account for the taxable year 1997.  At the hearing,            
          the Appeals officer provided petitioner with a copy of that                 
          document, as well as copies of several court cases, including               
          Pierson v. Commissioner, 115 T.C. 576 (2000).                               
               During the hearing, petitioner requested that the Appeals              
          officer identify the statutory provisions establishing                      
          petitioner’s liability for Federal income tax and provide                   
          verification that all applicable laws and administrative                    
          procedures had been followed in the assessment and collection               
          process.  Petitioner was informed that Form 4340 was sufficient             

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