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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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