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balance due. An additional notice of balance due was sent on
May 22, 2000.
On July 29, 2000, respondent issued to petitioner a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing with respect to the unpaid liabilities for 1997.
Petitioner returned to respondent a completed and signed Form
12153, Request for a Collection Due Process Hearing, with an
attachment in which he disputed, among other things, his receipt
and/or the validity of the underlying tax liability, the notice
of deficiency, the assessment, and the notice and demand for
payment.
A hearing was conducted on March 19, 2002. Both prior to
and at the hearing, petitioner was provided with copies of Form
4340, Certificate of Assessments, Payments, and Other Specified
Matters. Petitioner’s arguments at the hearing challenged the
collection action on grounds of liability, claiming a lack of
authority on the part of the Internal Revenue Service to assess
and collect the tax. Following the hearing, on March 29, 2002,
respondent issued to petitioner the Notice of Determination
Concerning Collection Actions(s) Under Section 6320 and/or 6330
sustaining the proposed levy.
Petitioner’s petition disputing respondent’s notice of
determination was filed on April 29, 2002, and reflected an
address in Fort Walton Beach, Florida. The petition raises
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