G. Robert Lyman and Shari Lee Wright Lyman - Page 6




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               would like to point out that the courts have previously                
               ruled against your arguments, and in some instances,                   
               have imposed sanctions.  I am hopeful that you wish to                 
               discuss legitimate issues and alternatives for resolv-                 
               ing your case at the hearing.                                          
               On April 5, 2002, the settlement officer held an Appeals               
          Office hearing with petitioners with respect to the notice of               
          intent to levy relating to petitioners’ taxable year 1998 and the           
          notice of tax lien relating to their taxable years 1997 and 1998.           
          At the Appeals Office hearing, the settlement officer gave                  
          petitioners, inter alia, Form 4340, Certificate of Assessments,             
          Payments, and Other Specified Matters, with respect to each of              
          their taxable years 1997 and 1998.                                          
               On May 16, 2002, the Appeals Office issued to Mr. Lyman a              
          notice of determination concerning collection action(s) under               
          section 6320 and/or 6330 (notice of determination) with respect             
          to the notice of intent to levy relating to taxable year 1998 and           
          issued to Ms. Lyman a separate notice of determination with                 
          respect to that notice of intent to levy.  On May 16, 2002, the             
          Appeals Office also issued to Mr. Lyman a notice of determination           
          with respect to the notice of tax lien relating to taxable years            
          1997 and 1998 and issued to Ms. Lyman a separate notice of                  
          determination with respect to that notice of tax lien.  An                  
          attachment to each of those four notices of determination stated            
          in pertinent part:                                                          








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