- 8 - 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, thePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011