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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.
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Last modified: May 25, 2011