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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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