Gary Gougler - Page 3




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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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