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C. Respondent’s Final Notice and Petitioner’s Response
On November 16, 2000, respondent sent the Schapers a Final
Notice-–Notice of Intent to Levy and Notice of Your Right to a
Hearing (the Final Notice). The Final Notice was issued in
respect of the Schapers’ outstanding tax liability for 1997.
On December 13, 2000, petitioner submitted to respondent a
Form 12153, Request for a Collection Due Process Hearing.
Petitioner’s request stated that he was challenging the validity
of the assessments for 1997 on the grounds there is no statute
imposing tax liability upon him and he was not served with a
valid notice and demand for payment.
D. The Appeals Office Hearing
By letter dated May 9, 2001, the Appeals Office provided
petitioner with a transcript of his account for the taxable year
1997. On June 14, 2001, Appeals Officer Wiley Davis conducted an
Appeals Office hearing that petitioner attended. According to a
purported transcript of the hearing prepared by petitioner,
petitioner declined to discuss collection alternatives. Rather,
petitioner stated that he wished to challenge his underlying tax
liability, and he requested that the Appeals officer provide
verification that all applicable laws and administrative
procedures were followed in the assessment and collection
process.
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Last modified: May 25, 2011