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On May 3, 2000, respondent issued to petitioner a notice of
intent to levy with respect to his assessed tax liability for
each of the years 1994 and 1996 (notice of intent to levy).
On June 1, 2000, petitioner timely filed Form 12153, Request
for a Collection Due Process Hearing (request for Appeals Office
hearing), with respect to the notice of intent to levy. In an
attachment to the request for Appeals Office hearing, petitioner
stated in pertinent part:
I am “challenging the appropriateness of (the) collec-
tion action” as specified in [section]6330(c)(2)(A)(ii)
since the IRS denied all of my requests for the initial
“examinations” and “interviews” as provided for in
Publications 1 & 5. In addition, no lien for taxes
pursuant to Code Sections 6321 and 6322 is possible
because no valid, underlying assessment was ever made.
In addition, I never received the statutory “notice and
demand” for payment of the taxes at issue as required
by Code Sections 6203, 6321, and 6331. If the appeals
officer is going to claim that a particular document
sent to me by the IRS was a “Notice and Demand” for
payment, then I am requesting that he also provide me
with a T.D. or Treas. Reg. which identifies that spe-
cific document as being the official, statutory “Notice
and Demand” for payment.
In addition, I am “challenging the existence of
the underlying tax liability” as I am authorized to do
in Code Section 6330(c)(2)(B). In addition, I did not
receive a (valid) notice of deficiency in connection
with any of the years at issue. I am also requesting
that the appeals officer have at the “Due Process
Hearing” a copy of the “Summary Record of Assessment”
(Form 23 C) together with the “pertinent parts of the
assessment which set forth the name of the taxpayer,
the date of the assessment, the character of the lia-
bility assessed, the taxable period, and the amount
assessed” as provided for in Treas. Reg. [section]
301.6203-1.
In addition, I want to see proof that a purported
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Last modified: May 25, 2011