Curtis B. Keene - Page 12




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          being rebuffed, the Appeals officer terminated the hearing.                 
          However, before doing so, the Appeals officer provided petitioner           
          with a copy of this Court’s opinion in Pierson v. Commissioner,             
          115 T.C. 576 (2000), advising that “It warns of bringing                    
          frivolous arguments before the court.”                                      
               F.  Respondent’s Notice of Determination                               
               On February 14, 2002, respondent’s Appeals Office issued to            
          petitioner a Notice of Determination Concerning Collection                  
          Action(s) Under Section 6320 and/or 6330 with regard to his tax             
          liabilities for 1997 and 1998.  In the notice, the Appeals Office           
          concluded that respondent’s determination to proceed with                   
          collection by way of levy should be sustained.                              
               G.  Petitioner’s Petition                                              
               On March 21, 2002, petitioner filed with the Court a                   
          Petition for Lien or Levy Action seeking review of respondent’s             
          notice of determination.8  The petition includes the following              
          allegations:  (1) The Appeals officer failed to obtain                      
          verification from the Secretary that the requirements of                    
          applicable law or administrative procedure were met as required             
          under section 6330(c)(1); (2) statutes making petitioner liable             
          for Federal income tax were not identified; (3) petitioner was              
          denied the opportunity to challenge the existence or amount of              


               8  At the time that the petition was filed, petitioner                 
          resided in Las Vegas, Nevada.                                               





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