- 4 - Trust was pending before the Court of Appeals for the Ninth Circuit. A face-to-face meeting was held between petitioner and an Appeals officer of respondent on August 16, 2002. On August 30, 2002, respondent issued to petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination). The notice of determination states: He [petitioner] wanted to see the physical documents that created the assessments. I told him that I had ordered a form 4340, Certificate of Official Record. This is sufficient proof for the Courts to show the assessment was properly made. Once this is received, I will mail him a copy and keep the originals in the file for the case record. Was the action legally and procedurally correct? I have reviewed the administrative file and the transcripts of the liability and determined that the proposed levy was legally and procedurally correct. The Appeals officer also concluded that respondent was not barred from collecting prior to the disposition of petitioner’s appeal because petitioner had not filed a bond as required by section 7485(a). Petitioner filed a timely petition for review of respondent’s determination. The only issue raised in the original petition was that collection was inappropriate because petitioner had filed an appeal with respect to the underlying tax liability that was pending before the Court of Appeals for thePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011