- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011