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Unless otherwise indicated, all section references are to the
Internal Revenue Code as amended.
Background
Petitioner resided in Phoenix, Arizona, at the time that she
filed her petition in this case. In response to a notice of
filing Federal tax lien for 1991, 1992, and 1993, petitioner sent
to the Internal Revenue Service (IRS) Office of Appeals a request
for a hearing dated September 27, 2000. The request contained
language challenging petitioner’s tax liability and IRS
procedures but did not address alternative methods of collection.
A hearing was held March 1, 2001, in response to
petitioner’s request. The Appeals officer commenced the hearing
by stating that the purpose of the hearing was “to explore
collection alternatives to the outstanding tax liability for the
tax periods 1991, 1992, and 1993.” Petitioner’s husband spoke
for petitioner at the hearing. The Appeals officer stated that
he had requested the Form 4340, Certificate of Assessments,
Payments and Other Specified Matters, and would mail it to
petitioner when it became available. Petitioner’s husband
asserted that the form had to be provided at the hearing.
Petitioner’s husband argued that “the IRS agency generally files
bogus tax returns for people”, petitioner was not required to
file a tax return, and petitioner had not received a valid notice
of deficiency.
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Last modified: May 25, 2011