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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.
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Last modified: May 25, 2011