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that applicable legal requirements and/or administrative
procedure have been met. Section 6330(c)(2)(A) details issues
that may be raised by a taxpayer at the hearing. The taxpayer
may raise “any relevant issue relating to the unpaid tax or the
proposed levy” including spousal defenses, challenges to the
appropriateness of collection action, and alternatives to
collection. Sec. 6330(c)(2)(A). Issues relating to the
underlying tax liability may not be raised if the taxpayer has
received a notice of deficiency or the taxpayer otherwise had an
opportunity to dispute the tax liability. See sec.
6330(c)(2)(B).
Petitioner, in his petition to this Court, alleged that,
during 1999, he was notified that he owed income tax and, to
date, he was not able to find out any factual information, even
though he had filed a request under the FOIA. Petitioner alleged
that the “errors by the I.R.S. is that there are no Factual
evidence in the claim against me, No persons name has come up
that I can find out how the claim came to be and for all
practical purpose[s] it seems that the figures used were made up
out of thin air.” Petitioner also made an allegation about his
disabled condition and status as a disabled veteran.
In subsequent documents filed with the Court, the gist of
petitioner’s contentions concerned his status as a disabled
veteran and his anger and fears connected with his legal
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Last modified: May 25, 2011