Wayne A. and Marykay Weishan - Page 8




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               We likewise reject petitioners’ assertion that the Appeals             
          officer failed to verify that all applicable laws and procedures            
          were complied with as required under section 6330(c)(1).  First,            
          the record shows that the letter that respondent issued to                  
          petitioners dated December 27, 1999, served as a notice and                 
          demand for payment.  In particular, the letter informed                     
          petitioners that changes had been made to their account for 1997            
          and requested that they pay the amount due by January 17, 2000.             
          The issuance of this letter corresponded with the date of                   
          assessment of tax, penalties, and interest as reflected in the              
          transcript of account that respondent provided to petitioners               
          before the Appeals Office hearing.  We hold that the letter                 
          constituted a notice and demand for payment within the meaning of           
          section 6303(a).  See, e.g., Hughes v. United States, 953 F.2d              
          531, 536 (9th Cir. 1992).                                                   
               We also reject petitioners’ assertion that the Appeals                 
          officer’s reliance on a transcript of account was insufficient              
          verification from the Secretary that the requirements of all                
          applicable laws and administrative procedures were met as                   
          required under section 6330(c)(1).  Petitioners assert that they            
          are entitled to a copy of a record of assessment.                           
               Federal tax assessments are formally recorded on a summary             
          record of assessment.  Sec. 6203.  The summary record of                    
          assessment must “provide identification of the taxpayer, the                






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