- 5 - respondent a Form 12153, Request for a Collection Due Process Hearing, challenging respondent’s Notice of Federal Tax Lien Filing. Petitioner’s request stated that he is not a taxpayer and that the payment of Federal income taxes constitutes a gift to the United States. D. The Appeals Office Hearing On March 23, 2001, Appeals Officer Angela M. Carmouche (the Appeals officer) conducted an Appeals Office hearing that petitioner attended. During the hearing, the Appeals officer provided petitioner with transcripts of account (MFTRAX) with regard to his taxable years 1995 and 1996. By letter dated April 23, 2001, the Appeals Office forwarded to petitioner Forms 4340, Certificate of Assessments, Payments, and Other Specified Matters, with regard to his taxable years 1995 and 1996. A copy of the Forms 4340, dated March 27, 2001, are attached to respondent’s Motion for Summary Judgment, which was served on petitioner. The Appeals Office also provided petitioner with a copy of the Court’s opinion in Pierson v. Commissioner, 115 T.C. 576 (2000). E. Respondent’s Notice of Determination On July 2, 2001, respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The notice stated that the Appeals Office hadPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011