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petitioners timely filed a Form 12153, Request for a Collection
Due Process Hearing.
On March 19, 2003, petitioners attended a section 6330
hearing with Appeals Officer Michael A. Freitag, who had no prior
involvement with respect to petitioners’ unpaid tax for 1997.
Respondent had denied petitioners’ request to record the hearing.
Appeals Officer Freitag provided petitioners with a Form 2866,
Certificate of Official Record, and a Form 4340, Certificate of
Assessments, Payments, and Other Specified Matters. The Form
4340 certified a deficiency of $408,247, a section 6651(a)(1)
failure-to-file addition to tax of $40,824.70, and a section 6662
accuracy-related penalty of $81,649. The Form 4340 certified
that respondent assessed the foregoing amounts and issued a
“statutory notice of balance due” on February 7, 2000. The Form
4340 further certified that respondent issued a “notice of
balance due” on May 21, 2001 and a “statutory notice of intent to
levy” on June 25, 2001. Respondent’s Supervisory Investigative
Analyst Lee Hansen signed the Form 4340 on February 7, 2003.
Appeals Officer Freitag also provided petitioners with the
following documents:
(1) A memorandum issued by respondent on May 2, 2002,
stating that respondent will not permit audio and stenographic
recordings of hearings before respondent’s Appeals Office;
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Last modified: May 25, 2011