Robert E. Crandall - Page 18

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          the taxpayer’s name, the date of assessment, the character of the           
          liability assessed, the taxable period, if applicable, and the              
          amounts assessed.  Sec. 6203; sec. 301.6203-1, Proced. & Admin.             
          Regs.  A taxpayer receiving a copy of Form 4340 has been provided           
          with all the documentation to which he or she is entitled under             
          section 6203 and section 301.6203-1, Proced. & Admin. Regs.                 
          Roberts v. Commissioner, supra at 370 n.7.  This Court likewise             
          has upheld collection actions where taxpayers were provided with            
          literal transcripts of account (so-called MFTRAX).  See, e.g.,              
          Frank v. Commissioner, T.C. Memo. 2003-88; Swann v. Commissioner,           
          T.C. Memo. 2003-70.  The February 20, 2003, letter to petitioner            
          from the Appeals officer stated that copies of “transcripts                 
          showing the contested assessments” would be available for                   
          petitioner.  The Court concludes that petitioner’s complaints               
          regarding the assessments and verification are meritless.                   
               Petitioner has denied receiving the notice and demand for              
          payment that section 6303(a) establishes should be given within             
          60 days of the making of an assessment.  However, a notice of               
          balance due constitutes a notice and demand for payment within              
          the meaning of section 6303(a).  Craig v. Commissioner, supra at            
          262-263.  The Forms 4340 indicate that petitioner was sent                  
          notices of balance due for each of the tax years involved.                  
               Thus, with respect to those issues enumerated in section               
          6330(c)(2)(A) and subject to review in collection proceedings for           

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