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(notice of intent to levy) with respect to his taxable year 1998.
On or about August 22, 2001, in response to the notice of intent
to levy, petitioner filed Form 12153, Request for a Collection
Due Process Hearing (Form 12153), and requested a hearing with
respondent’s Appeals Office (Appeals Office). A document that
petitioner attached to his Form 12153 (petitioner’s attachment to
Form 12153) stated in pertinent part:
I am requesting for [sic] a Collection Due Process
Hearing as provided for in Code sections 6320 and 6330.
* * * Thus, if any IRS employee attempts to deny me
the “Due Process Hearing” guaranteed to me by law, or
recommends that seizure action be taken without produc-
ing the documentation required by Sections 6320 and
6330 or without addressing the issues provided for in
these Code Sections, I will seek damages * * * and seek
that employee’s termination * * *.
* * * * * * *
It is clear before any Appeals officer can recommend
the seizure of any property pursuant to Code Section
6331 certain elements have to be present. For one
thing, pursuant to the statute, that person has to be
statutory [sic] “liable to pay” the taxes at issue, and
only after he “neglects or refuses to pay the same
within 10 days after notice and demand,” can his prop-
erty be subject to seizure. Therefore, apart from the
Appeals officer having to identify the statute that
makes me “liable to pay” the taxes at issue, he needs
to have a copy of the “notice and demand” which I
“neglected” and “refused” to pay. In addition, I
cannot be “liable” to pay an income tax, if the tax in
question has never been assessed against me as required
by Code Sections 6201 and 6203. So, I will need to see
a copy of the record of my assessments. As provided by
Code Section 6201(a)(1) and IRS Transaction Code 150,
all assessments have to be based on filed returns, I
will have to see a copy of the return upon which any
claimed assessment is based. In lieu of producing
these specific documents “verification from the Secre-
tary of the Treasury that the requirements of any
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