- 6 - Respondent did not hold an Appeals Office hearing with petitioner. That is because the Appeals officer determined that the matters advanced in petitioner’s attachments to Forms 12153 did not require respondent to hold a hearing to discuss those matters. The Appeals officer did advise petitioner in a letter (Appeals officer’s September 5, 2000 letter) that she was willing to examine any information that petitioner wished to submit showing that petitioner is not liable for the unpaid liabilities at issue, requesting an installment agreement, or requesting an offer in compromise. Petitioner did not provide any information in response to the Appeals officer’s September 5, 2000 letter. On March 22, 2001, the Appeals Office issued to petitioner a notice of determination concerning collection action(s) under section 6320 and/or 6330 (notice of determination). The notice of determination pertains to petitioner’s taxable years 1987, 1988, 1989, 1993, 1994, 1995, and 1996. An attachment to the notice of determination stated in pertinent part: MATTERS CONSIDERED AT THE APPEALS HEARING Applicable Law and Administrative Procedures • With the best information available, the require- ments of various applicable law and administrative procedures have been met. • Internal Revenue Code Section 6331(d) requires that 4(...continued) e.g., Copeland v. Commissioner, supra; Smith v. Commissioner, supra.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011