Harvey Doyne Perry, Jr. - Page 9

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          to satisfy the verification requirement of section 6330(c)(1).              
          The Appeals officer terminated the hearing after petitioner                 
          declined to discuss collection alternatives and instead persisted           
          in attempting to challenge the underlying tax liability.6                   
               E.  Respondent’s Notice of Determination                               
               On September 13, 2001, 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             
          liability for 1997.  In the notice, the Appeals Office concluded            
          that respondent’s determination to proceed with collection by way           
          of levy should be sustained.                                                
               F.  Petitioner’s Petition                                              
               On October 15, 2001, petitioner filed with the Court a                 
          Petition for Lien or Levy Action seeking review of respondent’s             
          notice of determination.7  The petition includes the following              

               6  The following colloquy between petitioner and the Appeals           
          officer exemplifies the administrative hearing:                             
                    PETITIONER: * * * I’m going to go and tell you                    
               that I cannot find anyplace in here [the Internal                      
               Revenue Code] a law that requires me to pay income tax.                
                              *  *  *  *  *  *  *                                     
                    APPEALS OFFICER:  Okay.  So it’s your position                    
               that there’s nothing in there that says you have to pay                
               income taxes?                                                          
                    PETITIONER:  Absolutely.                                          
               7  At the time that the petition was filed, petitioner                 

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