- 3 - Respondent assessed tax, penalties, and interest for petitioners’ 1993-96 tax years and sent them a notice of balance due for those years. Id. at 117-118. Prior to November 25, 1998, petitioners received a notice from respondent that respondent intended to collect tax owed by petitioners for those years by levy. Id. at 118. On November 25, 1998, respondent issued a notice of levy to two banks with respect to petitioners’ tax liabilities for 1993-95. Id. Respondent filed notices of Federal tax lien with respect to petitioners’ 1993-96 tax years on July 16, 1999. Id. at 118. Petitioners timely requested a hearing. Id. Respondent’s Appeals Office conducted the hearing and gave petitioners copies of Forms 4340, Certificate of Assessments and Payments, for 1993- 96. Id. at 119. After the hearing, respondent issued a notice of determination sustaining the notice of Federal tax lien. Id. at 119-120. Petitioners timely filed a petition with this Court to obtain judicial review of respondent’s notice of determination relating to the lien. A trial was held. On brief, petitioners said that the sole issue was whether the requirements for issuing a Form 4340 had been met. Id. at 120. In our opinion in that case, we held that the requirements for sustaining the notice of Federal tax lien had been met because Form 4340 establishes a presumption that tax was validly assessed, and petitioners hadPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011