Michael Schaper - Page 5




                                        - 5 -                                         
               C.  Respondent’s Final Notice and Petitioner’s Response                
               On November 16, 2000, respondent sent the Schapers a Final             
          Notice-–Notice of Intent to Levy and Notice of Your Right to a              
          Hearing (the Final Notice).  The Final Notice was issued in                 
          respect of the Schapers’ outstanding tax liability for 1997.                
               On December 13, 2000, petitioner submitted to respondent a             
          Form 12153, Request for a Collection Due Process Hearing.                   
          Petitioner’s request stated that he was challenging the validity            
          of the assessments for 1997 on the grounds there is no statute              
          imposing tax liability upon him and he was not served with a                
          valid notice and demand for payment.                                        
               D.  The Appeals Office Hearing                                         
               By letter dated May 9, 2001, the Appeals Office provided               
          petitioner with a transcript of his account for the taxable year            
          1997.  On June 14, 2001, Appeals Officer Wiley Davis conducted an           
          Appeals Office hearing that petitioner attended.  According to a            
          purported transcript of the hearing prepared by petitioner,                 
          petitioner declined to discuss collection alternatives.  Rather,            
          petitioner stated that he wished to challenge his underlying tax            
          liability, and he requested that the Appeals officer provide                
          verification that all applicable laws and administrative                    
          procedures were followed in the assessment and collection                   
          process.                                                                    








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011