Emil P. Tolotti, Jr. - Page 6

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          respondent issued to petitioner a notice and demand for payment             
          of the assessed amounts.                                                    
               During the Appeals Office hearing, petitioner requested that           
          the Appeals officer identify the statutory provisions                       
          establishing petitioner’s liability for Federal income tax.                 
          Petitioner was informed that although he would be permitted to              
          raise any valid challenge he might have to the specific amounts             
          of income that were reported to respondent by third-party payors,           
          he would not be permitted to raise constitutional challenges to             
          his underlying tax liability for 1995.  The Appeals officer                 
          terminated the hearing after petitioner declined to discuss                 
          alternatives to collection.                                                 
               On February 16, 2001, respondent issued to petitioner a                
          Notice of Determination Concerning Collection Action(s) Under               
          Section 6320 and/or 6330 stating that respondent’s determination            
          (that the filing of the Notice of Federal Tax Lien for                      
          liabilities owing for the taxable year 1995 is appropriate)                 
          should be sustained.  On March 2, 2001, petitioner filed with the           
          Court an imperfect Petition for Lien or Levy Action seeking                 
          review of respondent’s notice of determination.3  On April 6,               
          2001, petitioner filed an amended petition including the                    
          following allegations: (1) The Notice of Federal Tax Lien was not           

               3  At the time that the petition was filed, petitioner                 
          resided in Reno, Nevada.                                                    

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Last modified: May 25, 2011