Michael Cipolla - Page 6

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               monetary sanctions being imposed against you.  * * *                   
               On or about December 7, 2001, petitioner sent a letter to              
          the Appeals officer, responding to her December 5 letter.  That             
          response by petitioner included, inter alia, a challenge to the             
          underlying tax liability for 1997, as well as allegations                   
          including:  (1) Petitioner never received a “valid” notice of               
          deficiency; (2) no valid assessment of an income tax liability              
          for 1997 had been made against petitioner; and (3) petitioner had           
          not been issued a notice and demand for payment as required under           
          section 6303.  Petitioner also requested verification from the              
          Secretary that all applicable laws and administrative procedures            
          were followed with respect to the 1997 tax liability.                       
               On December 20, 2001, petitioner attended an administrative            
          hearing in New York City conducted by the Appeals officer.  At              
          the hearing, the Appeals officer provided petitioner with a                 
          literal transcript of petitioner’s account for 1997.                        
          Respondent’s Notice of Determination                                        
               On March 14, 2002, respondent’s Appeals Office issued                  
          petitioner a Notice of Determination Concerning Collection                  
          Action(s) Under Section 6320 and/or 6330, determining that the              
          proposed levy against him for 1997 should be sustained.                     
          Petitioner’s Petition and Respondent’s Motion To Have a Penalty             
          Imposed Against Petitioner Pursuant to Section 6673                         
               On April 8, 2002, petitioner filed with the Tax Court his              
          petition seeking review of respondent’s notice of determination.            





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