- 3 - 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:Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011