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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 transcripts, Forms 4340, were requested and
reviewed in addition to the tax return files for 1997
and 1998. * * *
* * * * * * *
The notice and demand letters were issued by regular
mail on May 18, 1998 for 1997 and on May 31, 1999 for
1998 to the taxpayer’s last known address as required
under IRC �6303. Letter 3172, meeting the notice
condition imposed by IRC �6320, was dated June 26,
2001 and sent to the taxpayer’s last known address by
certified mail. The taxpayers responded timely with a
Request for a Collection Due Process Hearing, Form
12153, received on July 13, 2001.
* * * * * * *
Issues Raised by the Taxpayer
* * * * * * *
Forms 2866, Certificate of Official Record, and Forms
4340, Certificate of Assessments, Payments, and Other
Specified Matters, were provided by mail to the taxpay-
ers in my hearing letter dated April 9, 2002. * * *
On May 6, 2002 when the taxpayers appeared for the
hearing, Mr. Horton, brought into the hearing a hand
held tape recorder. He was advised that the audio
recording would not be allowed per our prior telephone
conversation * * *. Mr. Horton, however, did record
our initial conversation and when this was discovered
he was asked to stop recording or the hearing would be
terminated. The taxpayers chose to terminate the
hearing and Mrs. Horton stated that they wished for
this brief meeting to be their due process hearing.
The hearing was concluded. Based on this, no issues
were raised by the taxpayers other than the lack of
opportunity to audio record the hearing and no collec-
tion alternatives were discussed at this meeting.
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