Cheryl D. Flathers - Page 12




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          petitioner secretly made an audio recording of her Appeals Office           
          hearing.  At the Appeals Office hearing, the settlement officer             
          gave petitioner Form 4340, Certificate of Assessments, Payments,            
          and Other Specified Matters (Form 4340), with respect to her                
          taxable year 1998.                                                          
               On July 11, 2002, the Appeals Office issued to petitioner a            
          notice of determination concerning collection action(s) under               
          section 6320 and/or 6330 (notice of determination) with respect             
          to petitioner’s unpaid liability for 1998 (notice of determina-             
          tion with respect to petitioner’s unpaid liability for 1998).3              
          An attachment to that notice stated in pertinent part:                      
               Verification of Legal and Procedural Requirements                      
               The Secretary has provided sufficient verification that                
               the requirements of any applicable law or administra-                  
               tive procedure have been met.                                          
               Certified account transcripts, Forms 4340, were re-                    
               quested and reviewed along with the administrative                     
               return file for 1998, which included the civil penalty                 
               work papers. * * *                                                     
                  *       *       *       *       *       *       *                   
               The collection due process and equivalency hearings                    


               3On July 11, 2002, the Appeals Office also issued to peti-             
          tioner (1) a notice of determination with respect to the frivo-             
          lous return penalty regarding petitioner’s 1998 return and (2) a            
          decision letter concerning equivalent hearing under sec. 6320               
          and/or 6330 (decision letter) with respect to the notice of                 
          intent to levy issued to petitioner with respect to the frivolous           
          return penalty regarding petitioner’s 1998 return (decision                 
          letter with respect to the frivolous return penalty regarding               
          petitioner’s 1998 return).                                                  






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