Crevenne C. and Barbara A. Carrillo - Page 7

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               On September 11, 2003, the Appeals officer attempted to hold           
          the scheduled conference with Mr. Carrillo, but Mr. Carrillo                
          refused to proceed when he was not permitted to record the                  
          hearing.  Thereafter, on January 21, 2004, respondent issued a              
          separate but identical Notice of Determination Concerning                   
          Collection Action(s) Under Section 6320 and/or 6330 to each                 
          petitioner sustaining the proposed lien and levy actions.  An               
          attachment to the notice addressed the various issues raised by             
          petitioners, indicated that petitioners were not entitled to                
          raise their underlying liabilities on account of failure to seek            
          prior available recourse in the District Court (for 1997 and                
          1998) or Tax Court (for 1999 and 2000), and pointed out that                
          petitioners had raised no issue as to collection alternatives.              
               Petitioners’ petition disputing the notices of determination           
          was filed on February 10, 2004, and reflected an address in Las             
          Vegas, Nevada.  In general, petitioners ask that the Court                  
          declare the notices of determination “null and void”.                       
          Petitioners’ complaints with respect to the administrative                  
          proceedings include the following:  No legitimate hearing under             
          section 6330 ever took place; petitioners were not permitted to             
          record a hearing; petitioners were denied the opportunity to                
          raise issues they deemed “relevant” (e.g., the “existence” of the           
          underlying tax liability); and requested documentation had not              
          been produced (e.g., record of the assessments, statutory notice            






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