- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011