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authority to assess tax. Petitioner also alleged that respondent
purportedly failed to enter valid assessments or produce a
“Summary Record of Assessment”. In addition, petitioner alleged
that respondent failed to issue to petitioner a “statutory”
notice and demand for payment of the taxes in question.
Petitioner attended an administrative hearing conducted by
Appeals Officer Kathleen Clark (Officer Clark) on March 18, 2003.
During the hearing, Officer Clark provided petitioner with copies
of Forms 4340, Certificate of Assessment, Payments, and Other
Specified Matters, regarding petitioner’s accounts for 1998 and
1999. The Forms 4340 showed that respondent had timely assessed
the taxes and additions to tax determined in the deficiency
notices for 1998 and 1999, and statutory interest and penalties
for failure to pay the taxes due. In addition, the Forms 4340
established that respondent had issued to petitioner a notice and
demand for payment of the assessed amounts for 1998 and 1999.
Both of the Forms 4340 included orthographic or numerical errors,
however, that had the effect of multiplying by one hundredfold
the total amounts due from petitioner for 1998 and 1999.
Specifically, although the line item entries in Forms 4340
included assessments that matched the total amounts listed as due
in the schedule attached to the final notice, the Forms 4340
erroneously stated that petitioner owed $71,745.45 and
$340,277.77 for 1998 and 1999, respectively.
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