- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011