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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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Last modified: May 25, 2011