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correct amount of tax, precluding the assessment of additional
amounts; (2) whether respondent had authority to determine or
collect additional tax; and (3) whether section 6331 applied in
this case.
A face-to-face hearing was held between petitioners and
respondent’s Appeals officer. The Appeals officer provided
petitioners with a transcript of their 1997 tax account.
Petitioners recorded and transcribed the hearing. In summary,
petitioners made the following assertions at the hearing: (1) The
Appeals officer had not obtained verification in accord with
section 6330 and that the administrative requirements were not
met with respect to the intent to levy; (2) that Government
employees committed fraud by altering and correcting a public
document; (3) that wages were not taxable because they do not
represent a profit; and (4) that the provisions of the Internal
Revenue Code, and in particular section 6331, did not apply to
petitioners because they applied only to U.S. Government
employees. The Appeals officer invited petitioners to discuss
less intrusive collection alternatives, but petitioners declined
other alternatives on the ground that they did not owe tax.
On July 25, 2001, after the hearing, the Appeals Office
mailed petitioners a notice of determination concluding that
respondent could proceed with collection based on the Appeals
officer’s findings and conclusions that (1) petitioners had been
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