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Hearing in respect of their outstanding tax liability for 1997.
On March 18, 2001, petitioners filed with respondent Form
12153, Request for a Collection Due Process Hearing. The
request, which was accompanied by a typewritten statement,
included, inter alia, a challenge to the existence of the
underlying tax liability, as well as allegations that petitioners
were never provided with a valid notice of deficiency or notice
and demand for payment. In addition, petitioners requested
verification from the Secretary that all applicable laws and
administrative procedures were followed with regard to the
assessment and collection of the tax liability in question.
D. The Appeals Office Hearing
On August 21, 2001, petitioners attended an administrative
hearing in Las Vegas, Nevada, conducted by Appeals Officer Tom
Aneau (the Appeals officer). Prior to the hearing, the Appeals
officer obtained and reviewed Form 4340, Certificate of
Assessments, Payments, and Other Specified Matters, pertaining to
petitioners’ account for 1997. At the hearing, the Appeals
officer provided petitioners with a copy of that document.
During the hearing, petitioners took the position that
payment of Federal income tax is voluntary and that “there is no
law that requires you to pay it.” Petitioners also requested
that the Appeals officer provide verification from the Secretary
of the Treasury that all applicable laws and administrative
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