- 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 werePage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011