- 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
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