- 4 - the taxes, additions to tax, and interest for all 5 years on March 19, 2001. Notices of balance due were sent to petitioner on that date, as well as on April 23, 2001. Subsequently, on September 16, 2002, respondent issued to petitioner a Final Notice--Notice of Intent to Levy and Notice of Your Right to a Hearing, with regard to the 1993 through 1997 years. Respondent on October 22, 2002, received from petitioner a Form 12153, Request for a Collection Due Process Hearing, setting forth his disagreement with the proposed collection action, as follows: (1) There was a failure to determine a deficiency; (2) There was a failure to issue a Notice of Deficiency; (3) Any Notice of Deficiency was void as it included income subject to Final Partnership Administrative Adjustments under TEFRA; (4) There was a failure to generate an assessment list; (5) There was a failure of the Commissioner to certify and transmit the assessment list; (6) There was a failure to record the assessment; (7) failure to provide record of assessment; and, (8) failure to send Notice of Assessment. By a letter dated January 29, 2003, the settlement officer to whom petitioner’s case had been assigned scheduled a hearing for February 19, 2003, in Phoenix, Arizona. The letter enclosed copies of Forms 4340, Certificate of Assessments, Payments and Other Specified Matters, for each of the years in issue. Petitioner appeared for the scheduled conference on February 19, 2003, accompanied by a stenographer and James Chisholm, who was identified as a witness. The settlement officer advised petitioner that recording and stenography were noPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011