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form to make an assessment, it did not constitute a signed
summary record of assessment); Crow v. Commissioner, supra (the
taxpayer argued that: (1) The Appeals officer failed to obtain
verification from the Secretary that the requirements of any
applicable law or administrative procedure were met; (2) the
Appeals officer failed to identify the statutes making the
taxpayer liable for Federal income tax; (3) the taxpayer was
denied the opportunity to challenge (a) the appropriateness of
the collection action, and (b) the existence or amount of his
underlying tax liability; and (4) the determination at issue was
invalid because the Appeals officer failed to establish due
process); and Newman v. Commissioner, supra (the taxpayers argued
that: (1) The Appeals officer failed to obtain verification from
the Secretary that the requirements of any applicable law or
administrative procedure were met; (2) the Appeals officer failed
to identify the statutes making the taxpayers liable for Federal
income taxes; (3) the taxpayers were denied the opportunity to
challenge (a) the appropriateness of the collection action, and
(b) the existence or amount of their underlying tax liabilities;
and (4) the determination at issue was invalid because the
Appeals officer issued the determination without conducting a
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