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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.
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