- 5 - attempted to challenge his underlying tax liability and demanded proof of his tax assessments, copies of Form 4340 (Certificate of Assessments, Payments, and Other Specified Matters), copies of his tax returns for the years at issue, and verification that all applicable laws and administrative procedures had been followed in the assessment and collection process. E. Respondent’s Notice of Determination On November 1, 2001, respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. In the notice of determination, the Appeals Office concluded that the proposed collection action should be sustained. F. The Petition On December 4, 2001, petitioner filed his petition with this Court seeking review of respondent’s notice of determination. The petition includes allegations that: (1) The Appeals officer failed to properly verify that the requirements of any applicable law or administrative procedure were met as required under section 6330(c)(1); (2) petitioner did not receive the requisite statutory notice and demand for payment or valid notice of deficiency; and (3) petitioner was denied the opportunity to 2(...continued) Revenue Code with that section marked liability for tax. If you could show me the statute that requires me to pay the tax, I am prepared to make arrangements to pay that which you say that I owe.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011