- 7 -
applicable law or administrative procedure have been
met,” will be acceptable. But, the Appeals officer
better have either the specific documents as identified
above, or “verification from the Secretary.” If the
Appeals officer can produce neither, then no Due Pro-
cess Hearing should have been scheduled. * * *
On February 5, 2002, respondent’s Appeals officer held an
Appeals Office hearing with petitioner with respect to the notice
of intent to levy. Prior to the Appeals Office hearing, the
Appeals officer provided petitioner with a literal transcript of
account with respect to petitioner’s taxable year 1998. After
the Appeals Office hearing, respondent’s representative provided
petitioner with Form 4340, Certificate of Assessments, Payments,
and Other Specified Matters (Form 4340), with respect to peti-
tioner’s taxable year 1998.
On March 19, 2002, the Appeals Office issued to petitioner a
notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). An attach-
ment to the notice of determination stated in pertinent part:
What issue is being appealed?
On August 30, 2001, the taxpayer submitted a timely
request, under Section 6330 of the Internal Revenue
Code (IRC), for a collection due process hearing. The
request relates to a Notice of Intent to Levy dated
August 6, 2001 that was issued for balances due on his
1998 individual income tax liability * * *.
Verification of Legal and Procedural Requirements
The Secretary has provided sufficient verification that
the requirements of applicable law and administrative
requirements have been met. I have reviewed tran-
scripts of the accounts, the taxpayer’s original 1998
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011