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requested a hearing and again disputed that sections of the “IRS
Code” related to the payment of tax applied to her.
On March 13, 2003, petitioner and petitioner’s witness Scott
Cousland attended a section 6330 hearing with Settlement Officer
Henry Lawler, Settlement Officer Maria Russo, and Appeals Team
Manager Ed Arcaro. At the hearing, respondent informed
petitioner that the Appeals Office would not consider arguments
based on constitutional, moral, religious, political, or similar
grounds. Petitioner requested to be shown where it says that she
has to pay taxes, and respondent provided the applicable Code
sections. Petitioner questioned how her tax liability had risen
to more than $6 million, as reported on the Form 4340,
Certification of Assessments, Payments, and Other Specified
Matters (Form 4340), dated January 27, 2003. Respondent
acknowledged that the Form 4340 was in error and informed
petitioner that corrected transcripts would be sent to her.3
Petitioner declined to discuss collection alternatives such as an
offer-in-compromise or an installment agreement. On March 24,
2003, respondent issued a corrected Form 4340 to petitioner
showing an assessment of $60,126.33.
On April 16, 2003, respondent issued a Notice of
Determination Concerning Collection Actions(s) Under Section 6320
3The transcript stated that the balance due was
$6,012,633.33. The actual assessed amount was $60,126.33.
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