- 4 - the Form 12153, petitioner alleged that the proposed levy was invalid for the following reasons: Included with the Notice of Intent to Levy there was no Assessment certificate--which means that no certifying officer is willing to accept responsibility (or liability) for the alleged liability. This fact denies me my opportunity for a meaningful hearing. Unless or until an assessment officer executes an assessment certificate in compliance with 26 CFR 301.6203-1, I am being deprived of PROCEDURAL due process. On July 25, 2001, an Appeals officer of respondent sent petitioner a letter scheduling a face-to-face meeting for August 16, 2001. Enclosed with the letter were Forms 4340, Certificates of Assessments, Payments, and Other Specified Matters, covering the assessments of petitioner’s liabilities for 1995, 1996, and 1997, which the letter stated were provided in response to petitioner’s request. On August 13, 2001, petitioner sent respondent a letter requesting that the hearing be conducted through written correspondence. On August 20, 2001, the Appeals officer sent petitioner a letter indicating that she would conduct the hearing through correspondence as petitioner had requested, and requesting that petitioner submit any additional materials or issues that he wished to be considered. No response was received to the Appeals officer’s letter. On November 21, 2001, respondent issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) with respect to the unpaid liabilities for 1995, 1996, and 1997. The notice ofPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011