Kenneth A. Sapp - Page 5

                                        - 5 -                                         
          petitioner submit completed Forms 433-A, Collection Information             
          Statement for Wage Earners and Self-Employed Individuals, and               
          433-B, Collection Information Statement for Businesses, as well             
          as completed Federal income tax returns for 1996 through 2000, by           
          August 3, 2001.  When petitioner had not responded by September             
          13, 2001, AO Ford sent him a letter on that date scheduling a               
          conference for October 9, 2001, to which petitioner was requested           
          to bring the foregoing materials.                                           
               Petitioner did not appear at the scheduled conference or               
          otherwise respond.  On February 5, 2002, Appeals issued a Notice            
          of Determination Concerning Collection Action(s) Under Section              
          6320 and/or 6330 (notice of determination) to petitioner, in                
          which it was determined that the levy should proceed because                
          petitioner had failed to attend the scheduled conference or                 
          otherwise respond to contacts by the Appeals officer.  The notice           
          of determination further observed that the 1990, 1991, 1992, and            
          1993 liabilities were based on returns filed for those years, and           
          the 1996 liability was based on information respondent had on               
          file.                                                                       
               Petitioner timely petitioned this Court for review, alleging           
          the following errors: (i) The notice of determination did not               
          state that AO Ford had no prior involvement with respect to the             
          tax periods at issue; (ii) the notice of determination did not              
          contain a verification that the requirements of applicable laws             






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011