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petitioner, and in a May 8, 2000, letter, responding to the
notice, petitioner acknowledged receipt of it and raised numerous
objections to it. Petitioner, however, did not petition this
Court with respect to the notice. In the notice, respondent had
determined a $19,949 income tax deficiency and a $2,572.42
penalty under section 6662(a) and (b)(1).
On March 1, 2001, respondent issued a Final Notice--Notice
of Intent to Levy and Notice of Your Right to a Hearing to
petitioner with respect to his 1998 tax liability. In a March
15, 2001, letter, petitioner requested a hearing. The Appeals
officer contacted petitioner and a date was set for a hearing.
The hearing was held on November 19, 2001, and petitioner and the
Appeals officer each made a tape recording of the conversation.
Petitioner contended that all of the administrative procedures
had not been met, and he also sought to challenge the underlying
tax liability. The Appeals officer provided petitioner with a
literal transcript of his tax account for the 1998 tax year which
reflected the steps taken by respondent before and after
assessment and up until the time of the hearing.
After the transcript was presented, petitioner contended
that the presentment was not in accord with the law, because the
statute required that the Appeals officer “shall at the hearing
obtain verification from the Secretary that the requirements of
any applicable law or administrative procedure have been met.”
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Last modified: May 25, 2011