- 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