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petitioner requested that the Appeals officer identify the
statutory provisions establishing petitioner’s liability for
Federal income tax and provide verification that all applicable
laws and administrative procedures were followed in the
assessment and collection process. Petitioner was again informed
that the transcripts of account provided to him before the
hearing were sufficient to satisfy the verification requirement
of section 6330(c)(1). Petitioner was also informed that he
would not be permitted to raise constitutional challenges to his
underlying tax liability for 1997. The Appeals officer
terminated the hearing after petitioner declined to discuss
alternatives to collection.4
F. Respondent’s Notice of Determination
On July 12, 2001, respondent’s Appeals Office issued to
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330. In the notice, the
Appeals Office stated that respondent’s determination to proceed
with collection by way of levy should be sustained. In an
attachment to the notice, the Appeals Office stated, in part, as
4 Petitioner stated that “I’ll pay the tax, just show me
the law that requires me to pay the tax.” The Appeals officer
identified sec. 1 as “the law that requires [petitioner] to pay
this tax.”. In this regard, sec. 1(c) imposes a tax on the
taxable income of unmarried individuals.
Near the end of the hearing, the Appeals officer also
provided petitioner with a copy of Pierson v. Commissioner, 115
T.C. 576 (2000), and suggested that he read that opinion. The
Pierson case is mentioned infra.
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