- 4 - hearing or to continue his hearing by correspondence. Petitioner chose to have his hearing conducted via correspondence. As part of the hearing, Appeals Officer Chambers reviewed the administrative file, which included the notices of deficiency and Forms 4340, Certificate of Assessments, Payments, and Other Specified Matters. Appeals Officer Chambers also reviewed a certified mail list, which was not part of the administrative file, to determine whether respondent mailed the notices of deficiency via certified mail to petitioner at his correct address. On July 28, 2003, petitioner sent Appeals Officer Chambers a letter in which he argued that in order to meet the verification requirement of section 6330(c)(1) respondent needed to establish that respondent properly (1) issued statutory notices of deficiency for the years in issue, (2) made the assessments for the years in issue, (3) issued notices and demand for payment, (4) issued notice of intent to levy, and (5) issued notice of petitioner’s right to a hearing. Petitioner also claimed he had not received any “assessment notices” from respondent for the years in issue. On October 8, 2003, respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) for the years in issue. Appeals Officer Chambers determined that the requirements ofPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011