- 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