- 8 - D. The Appeals Office Hearing Prior to an Appeals Office hearing, Appeals Officer Tony Aguiar (the Appeals officer) reviewed Form 4340, Certificate of Assessments, Payments, and Other Specified Matters, with regard to petitioners’ taxable year 1997. A copy of the Form 4340, dated December 27, 2000, is attached to respondent’s Motion for Summary Judgment, which was served on petitioners. On February 15, 2001, the Appeals officer conducted an Appeals Office hearing that petitioners attended. According to a purported transcript of the hearing prepared by petitioners, petitioners declined to discuss collection alternatives. Rather, petitioners stated that they wished to challenge their underlying tax liability, and they requested that the Appeals officer provide verification that all applicable laws and administrative procedures were followed in the assessment and collection process. E. Respondent’s Notice of Determination On March 9, 2001, respondent sent petitioners a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The notice stated that the Appeals Office had determined that it was appropriate for respondent to proceed with the collection of petitioners’ outstanding tax liability.6 6 The attachment (Form 3193) to the Notice of Determination, which was authored by the Appeals officer, states (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011