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Individual Income Tax Return, and the related defi-
ciency assessment file.
The statutory notice of deficiency was correctly sent
for the 1998 income tax assessment on February 18,
2000. The taxpayer received and responded to it with
frivolous arguments but did not petition the Tax Court.
The “notice and demand”, required by IRC 6303, was
properly sent to the taxpayers [sic] last known address
on August 7, 2000. The taxpayer has had an opportunity
for judicial review of the income tax assessment and is
now precluded, under IRC 6330(c)(2)(B) from raising
challenges “to the existence or amount of the underly-
ing tax liability”.
* * * * * * *
The Settlement Officer assigned to this hearing has had
no previous involvement with the taxpayer. * * * The
notice required by IRC 6330 was correctly sent and
resulted in this hearing request.
Relevant Issues Raised by Taxpayer
The hearing was conducted with the taxpayer on February
5, 2001 [sic]. The taxpayer’s hearing request pre-
sented only frivolous arguments and no relevant argu-
ments were presented at the hearing. The taxpayer
denied receipt of a Statutory Notice of Deficiency for
his 1998 liability, but he received and responded to it
and referenced in his letter dated March 6, 2000. That
letter also presented frivolous arguments and stated,
in part: “Nothing in the Privacy Act Notice or in the
above statutes informs me that I have to ‘comply’ with,
or pay attention to, letters and/or alleged ‘determina-
tions’ sent to me by various and sundry employees of
the IRS.” Only arguments of this vein were presented
at the hearing.
* * * * * * *
The taxpayer was specifically asked if he wished to
propose collection alternatives to levy on his assets
but he presented none. He was advised of his right to
judicial review of this determination. He was also
given a copy of Pierson v. Commissioner, 2000 U.S. Tax
Ct. LEXIS 93; 115 T.C. No.39 and was warned that the
courts have been imposing sanctions upon litigation of
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