Pepper Pot Trust, David-Keith Jacobs, Trustee - Page 4

                                        - 4 -                                         
               In March 2002, respondent’s Appeals Office conducted a                 
          section 6330(b) hearing in the trusts’ cases for tax years 1996-            
          97.  Shirley Clingenpeel (Clingenpeel), one of the grantors, and            
          Jacobs, the trustee, attended the hearing.  A reporter chosen by            
          the trusts recorded and transcribed the hearing.                            
               At the hearing, the hearing officer told Clingenpeel and               
          Jacobs that he had reviewed the administrative files and the                
          transcripts of accounts.  He used Forms 4340, Certificate of                
          Assessments and Payments, to verify the assessments; reviewed the           
          administrative record to verify that the requirements of all                
          applicable laws had been met; and concluded that the lien and               
          levy notices had been issued properly.                                      
               At the hearing, Clingenpeel and Jacobs did not offer any               
          collection alternatives or challenge the appropriateness of the             
          intended method of collection.  Jacobs gave the hearing officer a           
          document which asked him to produce or admit to 25 items.  At the           
          hearing, Jacobs asked for Form 23C, Assessment Certificate --               
          Summary Record of Assessments.  The Appeals officer told Jacobs             
          that he would not provide Forms 23C but he would send the trusts            
          copies of the Forms 4340 to verify the assessments.  Sometime               
          after the hearing, respondent gave each trust Forms 2866,                   
          Certificate of Official Record, and Forms 4340, which showed that           
          the amounts at issue were properly assessed.                                








Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011