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under section 6702 for 1997-2001. A Notice of Federal Tax Lien
was recorded in Salt Lake County, Utah.
On April 22, 2004, petitioner requested a hearing under
section 6330. In the hearing request, petitioner contended:
(1) No lien may be imposed because no valid assessment was made;
(2) he did not receive a statutory notice and demand as required;
(3) the Appeals officer must, but did not, give him the Treasury
directive or regulation that identifies the statutory notice and
demand for payment; (4) he may challenge the underlying tax
liabilities for 1998, 2001, and 2002, because he did not receive
a valid notice of deficiency for any of those years; (5) he is
entitled to, but did not, receive a copy of Form 23C; (6)
respondent must prove that respondent mailed a notice of
deficiency to him for each year in issue; and (7) the Appeals
officer must have at the hearing verification signed by the
Secretary showing that the requirements of any applicable law or
administrative procedure have been met.
Appeals Officer Bruce Skidmore (Skidmore) was assigned to
petitioner’s case. On June 18, 2004, Skidmore obtained computer
transcripts (transcripts) of petitioner’s accounts. In a letter
to petitioner dated August 30, 2004, Skidmore said: (1) He had
received petitioner’s request for a hearing; (2) the issues that
petitioner had raised in his request for a hearing were
frivolous, and he might be subject to sanctions; (3) petitioner
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