Robert Harold Hathaway - Page 9

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               Appeals Officer Kelly verified that the assessments in                 
          question were properly made.  He was not required to give                   
          petitioner a copy of the verification that the requirements of              
          any applicable law or administrative procedure have been met.               
          See Nestor v. Commissioner, 118 T.C. 162, 166 (2002).                       
               Appeals Officer Kelly provided petitioner with Forms 4340              
          for 1996 and 1997.  In this regard, see Lunsford v. Commissioner,           
          117 T.C. 183 (2001), and Davis v. Commissioner, 115 T.C. 35                 
          (2000), wherein we held that a Form 4340 may be used to verify              
          that a valid assessment was made.                                           
               Petitioner implies that Revenue Officer Gear did not have              
          authority to file a notice of Federal tax lien with the Clerk of            
          the Circuit Court, Marion County, Florida.  This assertion is not           
          valid.  In this regard, see Everman v. Commissioner, T.C. Memo.             
          2003-137, wherein we noted that the Commissioner has authority to           
          file a notice of Federal tax lien and that authority has been               
          delegated to a host of IRS personnel, including various managers            
          responsible for collection matters and GS-9 and above revenue               
          officers pursuant to Delegation Order No. 196 (Rev. 4; Oct. 4,              
               Simply stated, during the section 6330 hearing petitioner              
          had an opportunity to raise all relevant issues relating to the             
          existence and/or amount of his unpaid tax liabilities for 1996              
          and 1997.  He also had an opportunity to challenge the                      

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