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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...)
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