- 10 -
petitioner never received any notice and demand for payment.
Petitioner also requested verification from the Secretary that
all applicable laws and administrative procedures were followed
with regard to the assessment and collection of the tax
liabilities in question.
E. The Appeals Office Hearing
On February 6, 2002, petitioner attended an administrative
hearing in Las Vegas, Nevada, conducted by Appeals Officer Thomas
Lee Tracy (the Appeals officer). Prior to the hearing, the
Appeals officer reviewed transcripts of petitioner’s accounts for
1997 and 1998, as well as the original assessment files for those
years, and, by letter dated December 20, 2001, furnished
petitioner with copies of literal transcripts of his accounts for
6(...continued)
* * * I am not disputing the “amount” of the alleged
income tax “liability”, but the very “existence” of an
income tax “liability” as a matter of law. The Tax
Court, not being a court of law, has no jurisdiction to
even consider such a question.
In addition, the requests boast:
If * * * the appeals officer can point out such a
statute [i.e., “any statute that requires me ‘to pay’
income taxes”] at my DP [due process] hearing, I will
make arrangements to pay whatever amount the appeals
officer claims is due for my * * * income taxes.-and
the IRS won’t have to resort to seizures under Section
6331 to get it. Nor will there be any need for me to
appeal an adverse determination to Tax Court. So the
only reason for the appeals officer not to identify any
such statute is because no such statute exists.
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