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administrative procedures had been met and that the actions taken
or proposed by the revenue officer were appropriate under the
circumstances. The notice of determination, sent June 29, 2001,
concluded:
IRC sec. 6330 requires that the Appeals Officer
consider whether any collection action balances the
need for efficient collection of taxes with the
legitimate concern that any collection action be no
more intrusive than necessary. You did not appear at
the hearing, nor contact me in any way, or present an
acceptable alternative that is less intrusive than levy
action. Therefore, Appeals has determined the levy
action should be taken.
In his petition and at trial, petitioner attacked the credibility
of the Appeals officer, arguing that he attempted to contact the
Appeals officer with regard to the hearing. Petitioner argues
that the hearing should not have been conducted at the Internal
Revenue Service (IRS) office in Philadelphia, because petitioner
lives 75 miles away, and that the hearing should have been
conducted at a neutral place. Petitioner complains about
computer-generated documents, forms not signed by individuals,
and other alleged Government abuses. His main contention,
however, is that the IRS “stole” $2,000 from him in 1989.
At the time of trial, petitioner presented a notice dated
June 26, 1995, with respect to his tax liability for 1986, as
support for his argument that he did not receive a refund that
was due to him. The notice stated:
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Last modified: May 25, 2011