- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011