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requires that the taxpayer “have an opportunity to dispute such
tax liability.”
2. Petitioner’s Arguments Concerning the Underlying Tax
Liability.
As outlined previously, petitioner, contends that he was not
able to find out any factual information, even though he had
filed a request under the FOIA, and that he questions the
validity or substance of respondent’s determination. Petitioner
also contends that respondent has conspired with the NLRB as part
of a Governmentwide conspiracy against him and his family.
Regarding petitioner’s first contention, respondent’s
Appeals officer, in a letter to petitioner, provided him with an
explanation of the source of the income adjustments determined in
the statutory notice. She explained that the income items were
based on Forms W-2 and 1099 from petitioner’s own companies.
Petitioner wishes to ignore that information and instead argues
that respondent has failed to provide the information he asked
for in his FOIA request. Again, respondent’s Appeals officer
explained to petitioner, by letter, that his request had not been
honored because he refused or failed to agree to pay the required
fee.
Petitioner’s FOIA request was asking for the same
information as was provided by respondent’s Appeals officer;
i.e., the basis for the income tax liability. The documents upon
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Last modified: May 25, 2011