- 4 - deficient on it’s [sic] face because it is not in compliance with 26 USC section 6065. A face-to-face meeting was held between petitioners and an Appeals officer on August 22, 2001. On November 5, 2001, the Appeals officer issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, wherein he determined: (1) That the requirements of all laws and administrative procedures had been met; (2) that petitioners had had a prior opportunity to dispute the underlying tax liability and were thus precluded from contesting it in the collection proceeding; and (3) that no other issues had been raised. Based on these findings, the Appeals officer determined that the lien was appropriate. On January 31, 2002, petitioners filed their petition in the instant case. The petition raises several issues, including: (1) Whether “procedurally proper” versions of various documents were ever issued, including a notice of deficiency, a notice and demand for payment, and a notice of Federal tax lien; (2) whether petitioners’ liabilities were properly assessed; (3) whether the Appeals officer failed to verify that the requirements of any applicable law or administrative procedure were met, as required by section 6330(c)(1); and (4) whether respondent erred by failing to allow petitioners an examination interview and an administrative appeal prior to issuance of the notice ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011