- 5 -
Apparently, petitioner argued that the Secretary must personally
meet the verification requirement. Petitioner also contended
that, although he is required to comply with the statutes and
regulations, he does not have to comply with caselaw. Petitioner
admitted that he did not read any of the cases interpreting the
statutes and regulations. Petitioner also argued that respondent
had not shown him the particular laws that expressly state that
income is taxable to individuals or that define the term
“income”.
There was also a discussion of the statutory notice of
deficiency. Petitioner admitted that he had received the
document that the Appeals officer described as the Statutory
Notice of Deficiency, but petitioner contended that it was not a
“legal notice of deficiency” because it was not signed by the
Secretary or an authorized designee. Petitioner also made the
same argument with respect to whether the notice for payment was
a proper notice and demand for payment.
Accordingly, although petitioner received all of the
documents that respondent is required to provide before pursuing
collection, petitioner generally contended that the documents are
defective for lack of the Secretary’s signature or that they are
on the wrong form. In that regard, petitioner argued that
respondent was required to use a particular form in order to
satisfy the notice and demand requirement of the statute.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011