- 3 - to that record, “the Settlement Appeals Officer fully responded to petitioner’s challenge to the proposed collection action” and “fully complied with the requirements of Code section 6330(c)” and “there was no abuse of discretion”. Background The tax for each of the years in issue was assessed by respondent before the notice of determination was issued. For 1991, respondent assessed the tax after petitioner did not respond to a notice of deficiency that respondent had issued to petitioner. Petitioner had filed no return for the year. With respect to the other taxable years involved in this case, 1996, 1998, and 1999, petitioner did not pay all of the tax reported on the return filed for each of those years. Accordingly, respondent assessed the unpaid amounts. The record suggests that a notice of each of the above assessments and a demand for payment were issued to petitioner in accordance with section 6303(a). In due course thereafter, respondent issued to petitioner a final notice of intent to levy and notice of the right to a hearing, pursuant to section 6330(a). A copy of that notice is not included in the record.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011