- 10 - demands for payment; (5) documents showing that notices of deficiency were sent to petitioner; and (6) verification from the Secretary that the requirements of any applicable law or administrative procedure have been met. In a letter to petitioner dated September 10, 2004, Skidmore said that he was no longer available for a telephone conference on September 21, 2004, and that the Secretary need not personally verify that requirements of any applicable law or administrative procedure were met because the Secretary delegates that responsibility. In a letter to petitioner dated September 13, 2004, Skidmore said that there is evidence that petitioner had received the notice of deficiency and notice of lien. Skidmore also said that petitioner challenged the underlying tax liabilities on the grounds that he had not received a proper notice of deficiency and that petitioner had requested but not received written verification. Skidmore said petitioner had not raised any proper issues. Skidmore offered to speak to petitioner by telephone about the case on September 27 or 28, 2004. Skidmore asked petitioner to respond by 2:30 p.m. on September 28, 2004. On September 20, 2004, petitioner wrote Skidmore to say that a telephone conference is not acceptable, and that respondent must provide petitioner with: (1) A notice of deficiency and notice and demand for payment; (2) delegation orders from thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011