- 12 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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