Lionel D. Kolker - Page 8

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          of the proposed levy action.  Sec. 6330(c)(3).  The determination           
          of the Appeals officer under section 6330, except a determination           
          regarding the underlying tax liability that is made pursuant to             
          section 6330(c)(2)(B), is reviewed for abuse of discretion.  Sego           
          v. Commissioner, supra at 610.  Where the underlying tax                    
          liability is properly at issue, the Court reviews any                       
          determination regarding the underlying tax liability de novo.               
          Id.                                                                         
               A hearing officer may rely on a computer transcript or Form            
          4340, Certificate of Assessments, Payments and Other Specified              
          Matters, to verify that a valid assessment was made and that a              
          notice and demand for payment was sent to the taxpayer in                   
          accordance with section 6303.  Nestor v. Commissioner, 118 T.C.             
          162, 166 (2002).  Absent a showing of irregularity, a transcript            
          that shows such information is sufficient to establish that the             
          procedural requirements of section 6330 have been met.  Id. at              
          166-167.                                                                    
               In this case, the undisputed facts set forth in respondent’s           
          motion, declarations in support of the motion, and attached                 
          exhibits establish that respondent has satisfied the requirements           
          of section 6330.  Ms. Chadwell, who had had no prior involvement            
          with respect to the unpaid tax liabilities before the section               
          6330 hearing as required by section 6330(b)(3), verified that               
          proper assessments were made, as reflected on computer                      






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