William B. and Diane S. Meyer - Page 4

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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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