William G. Koenig - Page 9




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          Certificate of Assessments, Payments and Other Specified Matters,           
          pertaining to his account for the taxable year 1998.  At the                
          hearing, petitioner did not contradict the Appeals officer’s                
          assertion that petitioner had received the notice of deficiency             
          (see supra “B”).  However, petitioner did allege that he never              
          received “a statutory notice and demand for payment” (emphasis in           
          the original), and he requested a copy of the “summary record of            
          assessment”.  Petitioner also requested that the Appeals officer            
          provide verification that all applicable laws and administrative            
          procedures had been followed in the assessment and collection               
          process; in this regard, petitioner was informed by the Appeals             
          officer that the transcript provided (i.e., Form 4340) was                  
          sufficient to satisfy the verification requirement of section               
          6330(c)(1).  In addition, petitioner stated that he was                     
          challenging the underlying liability.  Finally, in response to              
          the Appeals officer’s question whether petitioner wished to                 
          discuss collection alternatives, petitioner stated that “I’m                
          prepared to pay * * * if you can convince me * * * where my                 
          liability is.”                                                              
               In a letter dated April 22, 2002, that was sent immediately            
          after the administrative hearing, the Appeals officer mailed                
          petitioner copies of relevant statutes and court cases, including           
          Davis v. Commissioner, T.C. Memo. 2001-87, in which this Court              
          imposed on the taxpayer a $4,000 penalty pursuant to section                






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