James E. Anderson and Cheryl J. Latos - Page 7

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               The Appeals officer upheld respondent’s determination to               
          proceed with collection action on petitioners’ outstanding tax              
          liabilities for 1995, 1996 and 1997.  For the 1996 and 1997 tax             
          liabilities, the Appeals officer concurred with the revenue                 
          agent’s report denying petitioners’ claims that they did not owe            
          income tax.  With respect to the 1995 tax liability, the Appeals            
          officer reviewed respondent’s computerized transcript of account            
          regarding petitioners’ 1995 liability, and the notice of                    
          deficiency issued by respondent for 1995.  In so doing, he                  
          verified that the 1995 liability was assessed after petitioners’            
          failure to file a timely petition in response to the May 6, 1997,           
          statutory notice.                                                           
               Concerning respondent’s determination to levy with respect             
          to the 1995, 1996, and 1997 tax liabilities, the Appeals officer            
          verified that respondent had complied with statutory procedural             
          requirements, including the issuance of a notice and demand to              
          pay and a notice of intent to levy which contained an explanation           
          of petitioners’ right to a hearing.  On October 29, 1999, Appeals           
          issued a Notice of Determination Concerning Collection Action(s)            
          Under Sections 6320 and/or 6330 to petitioners upholding                    
          respondent’s proposed collection action for taxable years 1995,             
          1996, and 1997.                                                             









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