George R. and Karen S. Kemper - Page 8

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               May 2, 2002 and forward.  Therefore you [sic] request                  
               to tape record and/or bring a court reporter * * * is                  
               denied.                                                                
               On August 29, 2002, a settlement officer held an Appeals               
          Office hearing with petitioner George R. Kemper (Mr. Kemper) with           
          respect to the notice of intent to levy.6  At the Appeals Office            
          hearing, the settlement officer gave Mr. Kemper Form 4340,                  
          Certificate of Assessments, Payments, and Other Specified Matters           
          (Form 4340), with respect to each of petitioners’ taxable years             
          1995, 1996, 1997, and 1998.                                                 
               On September 26, 2002, the Appeals Office issued a notice of           
          determination concerning collection action(s) under section 6320            
          and/or 6330 (notice of determination) to Mr. Kemper and a sepa-             
          rate notice of determination to Ms. Kemper.  (We shall refer                
          collectively to those two notices as petitioners’ notices of                
          determination.)  An attachment to each such notice of determina-            
          tion stated in pertinent part:                                              
               Verification of Legal and Procedural Requirements                      
               The Secretary has provided sufficient verification that                
               all legal and procedural requirements have been met.                   
               Appeals has reviewed computer transcripts verifying the                
               assessment.                                                            
               Assessments were made and the taxpayer was issued                      
               notice and demand letters by regular mail, to the                      
               taxpayer’s last known address, as required under IRC                   
               6303.  He neglected or refused to pay.  The notices                    
               required under IRC 6331(d) and IRC 6330 were combined                  

               6Petitioner Karen S. Kemper (Ms. Kemper) did not appear at             
          the Appeals Office hearing held on Aug. 29, 2002.                           





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