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Respondent further asserts that the Appeals officer’s review of
the individual master file transcript dated April 4, 2000, and
the TXMODA computer transcript dated June 30, 2000, satisfied the
verification requirement imposed under section 6330(c)(1).
Petitioner filed an Objection to respondent’s motion.
This matter was called for hearing at the Court's motions
sessions held in Washington, D.C., on November 21, 2001, and
January 23, 2002. Counsel for respondent appeared at the
hearings and presented argument in support of respondent's
motion. Respondent filed a Supplement to Motion for Summary
Judgment attaching thereto: (1) A copy of Form 4340, Certificate
of Assessments, Payments and Other Specified Matters, with
respect to petitioner’s 1995 tax year; (2) a declaration by
Appeals Officer Fisher; (3) a copy of the TXMODA computer
transcript for petitioner’s 1995 tax year; and (4) a transcript
of the Appeals Office hearing. Respondent also filed a Second
Supplement to Motion for Summary Judgment attaching thereto a
certified copy of the Notice of Federal Tax Lien filed with the
Washoe County Recorder in Reno, Nevada. Although no appearance
was made by or on behalf of petitioner at either of the hearings,
petitioner did file with the Court a written statement pursuant
to Rule 50(c) and a response to respondent’s motion, as
supplemented.
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