- 4 - The point is that the only assessment that can be made is off of a return and the return that I gave you had zeros on it. At the hearing, the settlement officer gave petitioner a literal transcript of assessments and notices. On October 5, 2001, a Form 4340, Certificate of Assessments, Payments, and Other Specified Matters, was mailed to petitioner. On November 1, 2001, respondent issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 which stated: A review of the case history indicates a valid assessment was made, notice and demand was provided and a neglect or refusal to pay occurred. In December of 1999 the taxpayer responded to a request for payment of the subject assessment with a letter questioning the governments’ [sic] authority to assess and collect tax. The Federal Tax Lien was filed in accordance with established procedures. The Federal Tax Lien is sustained. Proper administrative procedures were followed by Service personnel. This recommendation balances the need for efficient tax administration. Mr. Green has not proposed alternatives to the lien. On November 30, 2001, petitioner filed a petition with the Court in which he contended: (1) There was “no valid assessment” of taxes; (2) he did not receive the “statutory Notice and Demand for payment” of the taxes at issue; (3) he did not receive a valid notice of deficiency; and (4) he had no underlying tax liability. In the petition, petitioner argued that he did not receive the following documents at the hearing: (1) VerificationPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011