- 5 -
C. The Notice of Determination
On April 10, 2002, respondent sent each trust a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (the determination letter), in which respondent
stated that collection from each trust of its tax for tax years
1996-97 would proceed. Each trust filed a petition for review of
respondent’s notice of determination. The petitions contain the
following contentions and disputed facts: (1) Respondent has not
provided the trusts with Internal Revenue Code sections
establishing tax liability; (2) respondent has not provided the
trusts delegation authority for assessing tax; (3) respondent has
failed to provide Forms 23C; (4) the Forms 4340 for 1997 were
flawed and do not show the proper assessment of tax; (5) the
taxes for 1996 and 1997 were not legally assessed; (6) the
proposed levies were more intrusive than necessary; (7)
respondent’s determination of the trusts’ purported tax
liabilities, the filing of the Notices of Federal Tax Lien, and
respondent’s collection actions were based on hearsay evidence
and thus invalid; (8) respondent’s failure to give the trusts
Certificates of Assessment as requested denied them a meaningful
opportunity to dispute the lawful assessment of tax; and
(9) respondent cannot bring a collection action until respondent
gives the trusts certified evidence to support the claimed tax
liabilities.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011