Kevin P. Burke - Page 7

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          were invalid and that proper assessments were not entered for               
          several of the years in issue.  During the trial, and over                  
          petitioner’s objection, the Court allowed respondent to offer               
          into evidence Forms 4340, Certificate of Assessments, Payments              
          and Other Specified Matters, regarding petitioner’s account for             
          the years 1993 to 1997.  Following the trial, on March 11, 2005,            
          respondent’s Motion to Permit Levy was filed with the Court.                
                                       OPINION                                        
          I.  Collection Actions                                                      
          A.  Lien and Levy                                                           
               Sections 6320 (pertaining to Federal tax liens) and 6330               
          (pertaining to levies) establish procedures for administrative              
          and judicial review of certain collection actions.  As an initial           
          matter, the Commissioner is required to provide a taxpayer with             
          written notice that a Federal tax lien has been filed and/or that           
          the Commissioner intends to levy; the Commissioner is also                  
          required to explain to the taxpayer that such collection actions            
          may be challenged on various grounds at an administrative                   
          hearing.  See Davis v. Commissioner, 115 T.C. 35, 37 (2000); Goza           
          v. Commissioner, 114 T.C. 176, 179 (2000).                                  
               Section 6330(c)(1) imposes on the Appeals Office an                    
          obligation to obtain verification that “the requirements of any             
          applicable law or administrative procedure have been met.”                  
          Section 6330(c)(2) prescribes the matters that a person may raise           






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