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On March 15, 2001, a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 was sent to
petitioner. The notice stated in part:
During your hearing your arguments consisted of
disputing the assessment, notice and demand and receipt
of the Statutory Notice of Deficiency.
As explained to you during your hearing, you did not
file your tax returns for the periods 1991, 1992 and
1993 and therefore the Service filed returns for you
based on information filed with the IRS such as 1099
and W-2 information. A Statutory Notice of Deficiency
was mailed to you at your last known address, therefore
per IRC sec. 6330(c)(2)(B) you cannot challenge the
amount or existence of the liability. At your request
a transcript of your account will be sent to you
verifying the legality of the assessment and the fact
that payment has not been made.
You offered no collection alternatives in your hearing
even though you were requested to do so.
You offered no other collection alternatives or
challenges to the appropriateness of the collection
actions and because you offered no collection
alternatives to the lien and would not provide
financial information so collection alternatives to the
lien could be considered, it is the determination of
the Appeals Office that the Director of the Service
Center was correct when he determined the lien should
be filed.
In the petition, and in a subsequently filed Motion to
Dismiss for Lack of Jurisdiction, petitioner alleged, among other
things, that: (1) The Appeals officer was biased because he
notified her that arguments in her request for a hearing were
frivolous and without merit; (2) the Appeals officer “tried to
intimidate * * * [her] with threat of court sanctions”; (3) the
Appeals officer did not produce “verification from the Secretary
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Last modified: May 25, 2011