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Federal income taxes. Respondent then issued to petitioner on
August 14, 2000, the aforementioned “NOTICE OF DETERMINATION
CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330”.
The notice states:
Applicable Law & Procedures -
With the best information available, the requirements
of the various applicable law or administrative
procedures have been met.
* * * * * * *
Relevant Issues Presented by the Taxpayer -
1. Your only argument is that assessments were made on
guesses. You state that the IRS has the burden of
proof for income.
The underlying tax liability argument was not
addressed at the Appeals level. Since you had a
previous chance to contest this issue at U.S. Tax
Court and did not pursue that chance, the
underlying tax liability will not be an issue that
you can raise in this proceeding. You raised no
other issues relating to the unpaid taxes and made
no proposals regarding collection alternatives.
Balancing Efficient Collection and Intrusiveness -
There appears to be no other viable method to pay the
liability other than a levy. You have not given us any
other alternatives to settle your account. Therefore,
the determination is that the IRS may proceed with the
proposed levy action.
Petitioner’s petition disputing this notice was filed with
the Tax Court on September 18, 2000. Petitioner therein disputes
respondent’s determination on the following grounds:
a) The Commissioner has erroneously and wrongfully
included taxable income for 1989, 1990, 1991 when the
Petitioner did not have taxable income. The Petitioner
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