-3-
supporting financial information were incomplete. Petitioners
did not provide the complete information. On January 17, 2002, a
hearing was held between respondent’s Appeals officer and
petitioners’ counsel Judy E. Hamilton. In connection with the
hearing, the Appeals officer reviewed Internal Revenue Service
transcripts of account for petitioners’ 1994 and 1995 income tax
liabilities.
On April 12, 2002, respondent sent petitioners a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (Notice of Determination) regarding petitioners’ 1994
and 1995 income tax liabilities. On May 13, 2002, petitioners
filed with the Court a Petition for Lien or Levy Action. Neither
in the petition nor in the previous request for a hearing did
petitioners raise any issues with respect to the existence or the
amount of the underlying tax liability. Instead, petitioners
allege that they were denied their right to a hearing under
section 6330, that they were denied participation in the
proceedings relating to their offer in compromise, and that they
were subjected to punitive conduct by personnel of the Internal
Revenue Service (IRS). Petitioners ask the Court to remand this
case to Appeals for further consideration of an offer in
compromise or, alternatively, to transfer this case to the
appropriate Federal District Court.
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Last modified: May 25, 2011