- 11 -
by sections 6330 and 6331. One of the notices was for tax years
1991 through 1994; the other notice was for tax years 1990 and
1996.
Petitioner timely filed two requests, corresponding to the
two notices, for a section 6330 hearing. In his requests for
hearing, in response to the portion of the form asking why the
taxpayer does not agree with the proposed levy, petitioner
stated: “I was absent for three years due to illness and am in
the process of restructuring a stockholders note that will have a
significant effect on my tax consequences I request a personal
interview.”
Respondent’s Appeals officer held a hearing with petitioner
by telephone. Petitioner did not provide any documentary or
other evidence to the Appeals officer that he was medically
incapable of filing returns and waiving his rights to contest his
tax obligations prior to assessment. Petitioner was unable to
make the Appeals officer understand how the current restructuring
of a stockholder note would have any effect on his prior years’
tax liabilities, nor did he present any evidence to support any
reduction in those liabilities. Instead of responding to the
Appeals officer’s questions, petitioner talked about a perceived
conspiracy involving the vice president of Horn Construction, the
CIA, the FBI, the IRS, and the “Iranian Mafia”. The Appeals
officer also spoke on the telephone with petitioner’s accountant,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011