- 5 - anywhere on this, that there have been no determinations made with regard to James and Melanie Dunham. I don’t know what the facts are in the cases and I’m not going to address each of these arguments in any great exhausting detail, but there’s a reason why horse races are held, because you never know who’s going to win that race until the race is over. On February 27, 2002, a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 was sent to petitioners. The notice indicated the frivolous nature of petitioners’ arguments and stated: All statutory, administrative and procedural requirements have been met by the Internal Revenue Service prior to proposing the Notice of Levy. No viable alternatives to such action were established during Appeals consideration; accordingly, such action is not considered to be overly intrusive at this time. In the petition in this case, petitioners asserted: (1) No provision of the Internal Revenue Code makes them liable for the income tax and penalties determined in the statutory notice; (2) there was “no valid assessment” of taxes; (3) they did not receive a “notice and demand for payment” of the taxes at issue; (4) they did not receive a valid notice of deficiency; and (5) at the hearing they did not receive “verification from the Secretary that the requirements of any applicable law or administrative procedure have been met”. The same arguments were repeated in petitioners’ trial memorandum signed by Mr. Jewett and filed with the Court.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011