- 9 - 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 (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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