- 3 - obtained coded and noncoded (so-called “plain English”) versions of computer-generated transcripts (transcripts) of respondent’s records with respect to petitioner. Those transcripts identified petitioner, the type of tax assessed, the taxable period, the date of the assessment, and the amount assessed. At the Appeals Office hearing, the Appeals officer relied on the transcripts for the purpose of verifying that respondent made a valid assessment with respect to petitioner’s taxable year 1995. The Appeals officer provided to petitioner a copy of the plain English version of those transcripts at the Appeals Office hearing. On October 30, 2000, the Appeals Office issued to petitioner a “NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330" (notice of determination). That notice stated in pertinent part: (1) The only legal requirements before taking general enforcement action are the notice & demand and the notice of intent to levy and the notice of right to a collection due process hearing. The assessments were made, and notice & demand for payment, under IRC6303(a), were sent to your last known address, along with Publication 1, your rights as a taxpayer. You neglected or refused to pay the taxes and penalties due. Subsequently, you were sent the LT11 dated 4/28/2000. The Automated Collection System followed all legal & procedural requirements and the action proposed is appropriate under the circumstances, with regard to the income tax due for 1995 only. (2) The issues raised by you on your request are that, for the income tax due for 1995, you did not earn the alleged taxable income. For the Civil Penalties for 1996 & 1997, that the penalty is not based on agency records. With regard to the income tax due for 1995, the tax was assessed via a tax return filed by you onPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011