William Wilson - Page 6




                                        - 6 -                                         
               C.  Respondent’s Final Notice and Petitioner’s Response                
               On March 8, 2001, respondent sent petitioner a Final                   
          Notice-–Notice of Intent to Levy and Notice of Your Right                   
          to a Hearing (the Final Notice).  The Final Notice, issued in               
          respect of petitioner’s outstanding tax liabilities for 1996 and            
          1998, was signed by Scott Kilpatrick, identified as the Chief of            
          the Automated Collection Branch in Ogden, Utah.  On March 16,               
          2001, petitioner submitted to respondent a Form 12153, Request              
          for a Collection Due Process Hearing.  Petitioner’s request                 
          stated that he was challenging the validity of the assessments              
          for 1996 and 1998 on the grounds there is no statute imposing tax           
          liability upon him and he was not served with a valid notice and            
          demand for payment.                                                         
               D.  The Appeals Office Hearing                                         
               On October 9, 2001, Appeals Officers Tony Aguiar and Julie             
          Peterson (the Appeals officers) conducted an Appeals Office                 
          hearing that petitioner attended.  According to a purported                 
          transcript of the hearing prepared by petitioner, the Appeals               
          officers provided petitioner with Forms 4340, Certificate of                
          Assessments, Payments, and Other Specified Matters, with regard             
          to petitioner’s accounts for the years 1996 and 1998.  Copies of            
          the Forms 4340, dated September 4, 2001, are attached to the                
          petition that petitioner filed with the Court.  During the                  
          hearing, petitioner declined to discuss collection alternatives.            






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011