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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
(continued...)
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