Laura A. Gavigan - Page 12

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          D.  Verification That Requirements of Applicable Law or                     
          Administrative Procedure Have Been Met                                      
               At the CDP hearing, the officer must obtain verification               
          from the Secretary that the “requirements of any applicable law             
          or administrative procedure have been met”.  Sec. 6330(c)(1).               
          This verification requirement may be satisfied through Forms 4340           
          or transcripts of account.  Nestor v. Commissioner, 118 T.C. 162,           
          166 (2002); Davis v. Commissioner, 115 T.C. 35, 41 (2000).  The             
          officer is required only to obtain such verification before                 
          issuing a determination and is not required to provide a copy to            
          a taxpayer.  Nestor v. Commissioner, supra at 166-167.                      
               In the present case, the settlement officer not only                   
          obtained a copy of petitioner’s Form 4340, but provided a copy of           
          the Form 4340 to petitioner both prior to and at their face-to-             
          face meeting.  Accordingly, there was no abuse of discretion in             
          regard to whether the settlement officer verified that the                  
          requirements of any applicable law or administrative procedure              
          were met prior to issuing a determination in petitioner’s case.             
          E.  Relevant Issues at a CDP Hearing                                        
               A taxpayer may generally raise any relevant issue relating             
          to his or her unpaid tax liability or to the proposed levy,                 
          including appropriate spousal defenses, challenges to the                   
          appropriateness of collection actions, and offers of collection             
          alternatives.  Sec. 6330(c)(2)(A).  Where a taxpayer received a             
          statutory notice of deficiency, he or she is precluded from                 





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