Danney R. Land - Page 9




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               F.  Petitioner’s Petition                                              
               On January 2, 2002, petitioner filed with the Court a                  
          Petition for Lien or Levy Action seeking review of respondent’s             
          notice of determination.4  The petition includes allegations                
          that:  (1) The Appeals officer failed to obtain verification from           
          the Secretary that the requirements of any applicable law or                
          administrative procedure were met as required under section                 
          6330(c)(1); (2) the Appeals officer failed to identify the                  
          statutes making petitioner liable for Federal income tax; (3)               
          petitioner never received a “valid” notice of deficiency; i.e.,             
          “one signed by the Secretary or someone with delegated authority            
          from him”; (4) petitioner never received “the statutory ‘Notice             
          and Demand’ for payment”; and (5) petitioner was denied the                 
          opportunity to challenge the existence or amount of his                     
          underlying tax liability.  Petitioner also alleged that because             
          he “did not show a tax due on any of his returns for the years in           
          issue, no ‘deficiency’ pursuant to the provisions of [section]              
          6211 for those years was legally possible.”5                                

               4  Petitioner’s petition arrived at the Court in an envelope           
          bearing a U.S. Postal Service postmark date of November 7, 2001.            
          During the fall/winter of 2001-2002, the Court experienced                  
          significant delays in the receipt of mail because of anthrax.               
               At the time that the petition was filed, petitioner resided            
          in Boulder City, Nevada.                                                    
               5  Although petitioner speaks of his returns for the years             
          in issue, only the taxable year 1998 is involved in the present             
                                                             (continued...)           





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