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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...)
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