- 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