Emil P. Tolotti, Jr. - Page 8

                                        - 8 -                                         
          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                     

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011