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not shown any irregularity in respondent’s assessment procedures.
Id. at 120-122.
B. Respondent’s Notice of Levy for Petitioner’s Tax Years 1993-
2000 and Tina Nicklaus’s Tax Years 1993-94
Respondent prepared substitutes for petitioner’s returns for
tax years 1997-99 on February 1, 2001, and for 2000 on July 11,
2002. Respondent issued notices of deficiency to petitioner for
1997-2000 on dates not stated in the record. Petitioner did not
file a petition in this Court for those years. Respondent
assessed tax, additions to tax, and interest for petitioner’s tax
years 1997-99 on July 14, 2003, and for his tax year 2000 on
September 8, 2003.
On September 9, 2004, respondent sent a Final Notice -
Notice of Intent to Levy and Notice of Your Right to a Hearing to
Tina Nicklaus for income taxes for 1993 and 1994 and to
petitioner for 1993-2000. Petitioners filed separate requests
for a hearing under section 6330(b).
Appeals Officer Jean Duncan (Duncan) was assigned to
petitioners’ case. Duncan gave petitioners Forms 4340 for 1993-
2000 before the hearing under section 6330(b). As part of their
section 6330(b) hearing, petitioners gave Duncan seven documents
including petitioner’s description of respondent’s actions with
respect to petitioners’ 1993-2000 tax years and copies of various
transcripts.
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