- 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 of
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011