- 7 - includes an IMF MCC3 transcript of account, dated December 18, 2000, regarding petitioners’ 1997 taxable year. On July 30, 2001, the Appeals officer conducted an Appeals Office hearing that petitioner Rainer Wagner attended. According to a purported transcript of the hearing prepared by petitioners, petitioner Rainer Wagner offered to pay the amount due for 1997 only if the Appeals officer would show him the Internal Revenue Code provisions making petitioners liable for Federal income taxes. The Appeals officer terminated the hearing when petitioner failed to raise any valid issue. E. Respondent’s Notice of Determination On September 21, 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 for 1997. F. Petitioners’ Petition On October 17, 2001, petitioners filed with the Court a petition for lien or levy action seeking review of respondent’s notice of determination.4 The petition includes allegations 3 IMF MCC stands for “Individual Master File-Martinsburg Computing Center”. 4 At the time the petition was filed, petitioners resided (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011