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petitioner’s liability for Federal income tax and provide
verification that all applicable laws and administrative
procedures were followed in the assessment and collection
process. Petitioner was informed that the literal transcript, as
well as the more technical IMF (individual master file)
transcript, were sufficient to satisfy the verification
requirement of section 6330(c)(1). The Appeals officer
terminated the hearing after petitioner declined to discuss
collection alternatives and instead persisted on attempting to
challenge the underlying tax liability.
E. Respondent’s Notice of Determination
On May 9, 2001, respondent’s Appeals Office issued to
petitioner and his wife a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 with regard
to their tax liability for 1997. In the notice, the Appeals
Office concluded that respondent’s determination to proceed with
collection by way of levy should be sustained.
F. Petitioner’s Petition and Motion To Dismiss
On June 7, 2001, petitioner filed with the Court a Petition
for Lien or Levy Action seeking review of respondent’s notice of
determination.5 The petition includes the following allegations:
(1) The Appeals officer failed to obtain verification from the
5 At the time that the petition was filed, petitioner
resided in Las Vegas, Nevada.
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