- 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