- 10 - requires that the taxpayer “have an opportunity to dispute such tax liability.” 2. Petitioner’s Arguments Concerning the Underlying Tax Liability. As outlined previously, petitioner, contends that he was not able to find out any factual information, even though he had filed a request under the FOIA, and that he questions the validity or substance of respondent’s determination. Petitioner also contends that respondent has conspired with the NLRB as part of a Governmentwide conspiracy against him and his family. Regarding petitioner’s first contention, respondent’s Appeals officer, in a letter to petitioner, provided him with an explanation of the source of the income adjustments determined in the statutory notice. She explained that the income items were based on Forms W-2 and 1099 from petitioner’s own companies. Petitioner wishes to ignore that information and instead argues that respondent has failed to provide the information he asked for in his FOIA request. Again, respondent’s Appeals officer explained to petitioner, by letter, that his request had not been honored because he refused or failed to agree to pay the required fee. Petitioner’s FOIA request was asking for the same information as was provided by respondent’s Appeals officer; i.e., the basis for the income tax liability. The documents uponPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011