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Request for a Collection Due Process Hearing, requesting a
hearing for taxable years 1991, 1992, 1993, 1994, and 1997, that
respondent deemed timely. On December 5, 2001, a hearing with an
Appeals officer of respondent was conducted by telephone.
Petitioner Simon Richard brought to the Appeals officer's
attention his claim that the payments he made pursuant to the
1993 installment agreement had been improperly applied to a
purported liability for 1991. Mr. Richard further advised the
Appeals officer of his contention that the 1991 liability, to
which the 1993 installment agreement payments were applied, had
been assessed beyond the 3-year period of limitations on
assessment. In her subsequent determination, the Appeals officer
concluded that the Appeals Office lacked jurisdiction over
petitioners' 1991 taxable year and that petitioners' foregoing
contentions could therefore not be considered as part of the
hearing.
On October 23, 2002, a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 was mailed to
petitioners in which the Appeals officer determined that all
requirements of any applicable law or administrative procedure
had been met and that the lien was appropriate to collect
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Last modified: May 25, 2011