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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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