- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011