- 5 -
enforced collection action against my client can’t lawfully
proceed. Okay.
At the hearing, Mr. Jewett presented the Appeals Office with
various exhibits filled with basic tax-protester arguments.
On April 10, 2002, a Notice of Determination Concerning
Collection Action(s) Under Section 6320/6330 was sent to
petitioner. The notice stated:
During the March 28, 2002 office hearing, Mr. Jewett
and yourself were advised of the above limitations on issues
that could be raised or would be considered at the hearing.
You were advised of possible sanctions under IRC �6673 for
maintaining frivolous arguments. You were advised Appeals
is relying on Form 4340 to verify that a valid assessment
was made, IRC �6303(a), Notice and Demand, and IRC �6331,
Notice of Intent to Levy were issued, and your own
acknowledgment of receipt of the notice of deficiency to
limit challenges to the underlying liability.
Additional correspondence was received from Mr. Jewett
and yourself, which have been considered in the
determination. No other non-frivolous issues were raised.
As a result, respondent sustained the proposed levy with regard
to the 1998 tax liability.
In the petition in this case, signed by Mr. Jewett,
petitioner asserted:
The decision of the hearing officer is incorrect for the
reasons set forth in the attached supplement to this
Petition, in addition to the fact that the IRS has not
complied with the applicable laws and administrative
procedures, the collection procedures are inappropriate and
illegal, and Gregory R. Brown has no liability for the taxes
and penalties at issue.
Mr. Jewett attached to the petition a six-page supplement filled
with similar tax-protester arguments. The same arguments were
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011