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On January 12, 2001, respondent’s Appeals officer held an
Appeals Office hearing with petitioner with respect to the notice
of lien. At the Appeals Office hearing, the Appeals officer gave
petitioner Form 4340, Certificate of Assessments, Payments, and
Other Specified Matters, with respect to each of his taxable
years 1996 and 1997.
On January 25, 2001, the Appeals Office issued to petitioner
a notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination).7 An attach-
ment to the notice of determination stated in pertinent part:
MATTERS CONSIDERED AT APPEALS
Applicable Law and Administrative Procedures
Based on the information available, the requirements of
applicable law and administrative procedures have been
met.
Internal Revenue Code Section 6321 provides for a
statutory lien when a taxpayer neglects or refuses to
pay a tax liability after notice and demand. Tran-
scripts show notice and demand was issued.
Internal Revenue Code Section 6320(a) requires that the
Internal Revenue Service notify a taxpayer of a notice
6(...continued)
statements, contentions, arguments, and requests contained in the
attachments to Forms 12153 filed with the Internal Revenue
Service by certain other taxpayers with cases in the Court. See,
e.g., Copeland v. Commissioner, T.C. Memo. 2003-46; Smith v.
Commissioner, T.C. Memo. 2003-45.
7On Jan. 25, 2001, respondent issued to petitioner a sepa-
rate notice of determination with respect to the frivolous return
penalty under sec. 6702 regarding each of his returns for 1996
and 1997.
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