Thomas W. Roberts - Page 4




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               C is attached.  (Do not send a RACS Report or an Indi-                  
               vidual Master File, as these are not responsive to this                 
               request).  As this request is placed under an act of                    
               Congress, The Privacy Act, it supersedes any agency                     
               policy preventing the disclosure of the signed assess-                  
               ment.                                                                   
                                                                                      
               On January 5, 1999, the Disclosure Office sent a letter                 
          (January 5, 1999 Disclosure Office letter) to petitioner in                  
          response to his December 21, 1998 request.  That letter stated in            
          pertinent part:                                                              
               In your letter you requested a copy of Form 23-C for                    
               the tax year 1996.  All 23-C assessment documents would                 
               be available only from the service center where the                     
               assessment was made.  In your case however, there have                  
               been no assessments other than the processing of your                   
               tax return plus penalty and interest.  We are enclosing                 
               a transcript for your reference.                                        
               On October 11, 1999, respondent issued to petitioner a final            
          notice of intent to levy with respect to petitioner’s taxable                
          year 1996 (final notice of intent to levy).  Thereafter, on a                
          date not disclosed by the record, petitioner requested a hearing             
          with the IRS Appeals Office (Appeals Office) with respect to that            
          notice.  On August 8, 2000, the Appeals Office held a hearing                
          with petitioner with respect to the final notice of intent to                
          levy.                                                                        
               On January 12, 2001, the Appeals Office issued to petitioner            
          a “NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER             
          SECTION 6320 and/or 6330" (notice of determination) with respect             
          to petitioner’s taxable year 1996.  That notice stated in perti-             
          nent part:                                                                   





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