Gary Wright - Page 17

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          Regs.  A taxpayer receiving a copy of Form 4340 has been provided           
          with all the documentation to which he or she is entitled under             
          section 6203 and section 301.6203-1, Proced. & Admin. Regs.                 
          Roberts v. Commissioner, supra at 370 n.7.  This Court likewise             
          has upheld collection actions where taxpayers were provided with            
          literal transcripts of account (so-called MFTRAX).  See, e.g.,              
          Frank v. Commissioner, T.C. Memo. 2003-88; Swann v. Commissioner,           
          T.C. Memo. 2003-70.  The November 19, 2003, letter to petitioner            
          from Mr. Freitag enclosed copies of Forms 4340.  Furthermore,               
          arguments similar to petitioner’s statements concerning copies of           
          the tax returns from which assessments were made have been                  
          summarily rejected.  See, e.g., Bethea v. Commissioner, T.C.                
          Memo. 2003-278; Fink v. Commissioner, T.C. Memo. 2003-61.  The              
          Court concludes that petitioner’s complaints regarding the                  
          assessments and verification are meritless.                                 
               Petitioner has also raised the notice and demand for payment           
          that section 6303(a) establishes should be given within 60 days             
          of the making of an assessment.  However, a notice of balance due           
          constitutes a notice and demand for payment within the meaning of           
          section 6303(a).  Craig v. Commissioner, supra at 262-263.  The             
          Forms 4340 indicate that petitioner was sent notices of balance             
          due for each of the tax years involved.                                     
               Thus, with respect to those issues enumerated in section               
          6330(c)(2)(A) and subject to review in collection proceedings for           






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Last modified: May 25, 2011