Roy Watson - Page 4




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          proposed collection action for the period(s) shown above.  This             
          letter is your legal Notice of Determination, as required by                
          law.”  The notice includes the following “Summary of                        
          Determination”:  “It is Appeals’ decision that Collection be                
          allowed to proceed with the appropriate collection action.”                 
          Accompanying the notice is the following explanation:                       
               Attachment - 3193                                                      
                        ENCLOSURE TO NOTICE OF DETERMINATION                          
                                    ROY A. WATSON                                     
               The Secretary has provided sufficient verification                     
               that the requirements of any applicable law or                         
               administrative procedure have been met.                                
               Your request for a hearing with Appeals was made under                 
               IRC �6330 to prevent appropriate collection action.                    
               You state in your request that you deny that you had                   
               income for 1991 and 1992 that is subject to tax.  Tax                  
               was assessed for the years 1991 and 1992 under IRC                     
               �6020(b) because you failed to voluntarily file income                 
               tax returns.  You were provided an opportunity to                      
               dispute the assessments.  You responded with                           
               arguments previously determined by the courts to be                    
               frivolous.  IRC �6330(c)(2)(B) precludes you from                      
               raising liability as an issue at your hearing.  You                    
               were offered the opportunity for a hearing with Appeals                
               to discuss alternative collection proposals and the                    
               filing of corrected returns for the years at issue.                    
               You did not respond.                                                   
               Without further cooperation, it is Appeals decision                    
               that the proposed collection action balances the need                  
               for efficient collection of taxes with the taxpayer’s                  
               legitimate concern that any collection action be no                    
               more intrusive than necessary.                                         
               In the petition, petitioner assigns the following errors:              








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