- 5 - taxable year 1999. At that hearing, the settlement officer also gave petitioner a copy of Pierson v. Commissioner, 115 T.C. 576 (2000), and explained the warning of the Court in that Opinion with respect to section 6673(a)(1). On November 4, 2003, the Appeals Office issued to petitioner a notice of determination concerning collection action(s) under section 6320 and/or 6330 (notice of determination). That notice of determination stated in pertinent part: Summary of Determination Appeals determination is that Compliance is upheld. No relief is granted. You were given an opportunity to prepare and file corrected returns and provide a com- pleted Collection Information Statement. You failed to file corrected returns. You did not provide any finan- cial information on which consideration of alternatives could be based. You raised only frivolous arguments and were given a copy of Pierson v. Commissioner. An attachment to that notice of determination stated in pertinent part: SUMMARY AND RECOMMENDATION You requested a Collection Due Process (CDP) Hearing with Appeals under the provisions of IRC �6330. -The determination of Appeals is that the proposed collection actions are appropriate and are upheld. No relief is granted. * * * * * * * VERIFICATION OF LEGAL AND PROCEDURAL REQUIREMENTS: The statute of limitations has been suspended since 12/09/2002. The Settlement Officer had no involvement in your case prior to the assignment for the CDP Hear- ing.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011