- 5 - Duncan reviewed respondent’s administrative records for petitioners and all documents submitted by petitioners. Duncan considered petitioners’ arguments and concluded that petitioners had not shown that there were any irregularities in assessment procedures for the years in issue. Respondent sent petitioners a Notice of Determination with respect to the levy concerning their income tax liability for 1993 and 1994 on April 15, 2004. Respondent sent a Notice of Determination to petitioner with respect to the levy concerning income tax he owed for 1995-2000 on April 15, 2004. Petitioners timely filed a petition in this Court. On Forms 4340 for 1995 and 1996, Tina Nicklaus’s Social Security number is partially incorrect and petitioner’s first name is misspelled. OPINION A. Contentions of the Parties and Background Petitioners contend that respondent’s transcripts show that respondent did not follow proper assessment procedures and that this Court lacked jurisdiction in their prior case before this Court and in this case. Petitioners ask that we vacate the decision in their prior case and that we remand this case to respondent.1 1 Petitioners do not contend that sec. 7491(a) applies in this case and have not established that they met the requirements of sec. 7491(a)(2).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011