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being rebuffed, the Appeals officer terminated the hearing.
However, before doing so, the Appeals officer provided petitioner
with a copy of this Court’s opinion in Pierson v. Commissioner,
115 T.C. 576 (2000), advising that “It warns of bringing
frivolous arguments before the court.”
F. Respondent’s Notice of Determination
On February 14, 2002, respondent’s Appeals Office issued to
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 with regard to his tax
liabilities for 1997 and 1998. In the notice, the Appeals Office
concluded that respondent’s determination to proceed with
collection by way of levy should be sustained.
G. Petitioner’s Petition
On March 21, 2002, petitioner filed with the Court a
Petition for Lien or Levy Action seeking review of respondent’s
notice of determination.8 The petition includes the following
allegations: (1) The Appeals officer failed to obtain
verification from the Secretary that the requirements of
applicable law or administrative procedure were met as required
under section 6330(c)(1); (2) statutes making petitioner liable
for Federal income tax were not identified; (3) petitioner was
denied the opportunity to challenge the existence or amount of
8 At the time that the petition was filed, petitioner
resided in Las Vegas, Nevada.
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