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Rather, petitioner stated that he wished to challenge his
underlying tax liabilities, and he requested that the Appeals
officers provide verification that all applicable laws and
administrative procedures were followed in the assessment and
collection process.
E. Respondent’s Notice of Determination
On December 6, 2001, respondent sent petitioner 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 petitioner’s outstanding tax liabilities for
1996 and 1998.
F. Petitioner’s Petition
On December 26, 2001, petitioner filed with the Court a
petition for lien or levy action seeking review of respondent’s
notice of determination.3 The petition includes allegations
that: (1) The Appeals officers failed to obtain verification
from the Secretary that the requirements of any applicable law or
administrative procedure were met as required under section
6330(c)(1); (2) petitioner never received a notice and demand for
payment or valid notice of deficiency; and (3) the Final
3 At the time that the petition was filed, petitioner
resided in Las Vegas, Nevada.
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