- 9 - 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 sectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011