- 4 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011