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On May 6, 2002, the settlement officer held an Appeals
Office hearing with petitioners with respect to the notice of tax
lien relating to petitioners’ taxable years 1997 and 1998.
Petitioners secretly made an audio recording of part of their
Appeals Office hearing. When the settlement officer discovered
that petitioners were secretly recording their Appeals Office
hearing, she asked them to stop recording the hearing and indi-
cated that if they did not, the hearing would be terminated.
Thereafter, the hearing was terminated. Prior to the Appeals
Office hearing, the settlement officer gave petitioners Form
4340, Certificate of Assessments, Payments, and Other Specified
Matters, with respect to each of their taxable years 1997 and
1998.
On July 16, 2002, the Appeals Office issued a notice of
determination concerning collection action(s) under section 6320
and/or 6330 (notice of determination) to petitioner Albert Horton
and a separate notice of determination to petitioner Ramona
Osborne. (We shall refer collectively to those two notices as
petitioners’ notices of determination). An attachment to each
such notice of determination stated in pertinent part:
7(...continued)
settlement officer assigned to conduct a hearing regarding the
notice of tax lien with respect to petitioners’ unpaid
liabilities for 1997 and 1998 promptly notified petitioners about
that change.
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Last modified: May 25, 2011