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Type of tax Period Amount
1040 12/31/1995 $136.09
1040 12/31/1996 287.98
1040 12/31/1997 17,426.84
1040 12/31/1998 2,620.07
1040 12/31/1999 21,266.89
On February 15, 2001, respondent issued to petitioner a Letter
1058, Final Notice--Notice of Intent to Levy and Notice of Your
Right to a Hearing. Petitioner filed Forms 12153, Request for a
Collection Due Process Hearing, with respect to the notice of
lien filing for the 1995, 1996, 1997, 1998, and 1999 tax
liabilities and with respect to the notice of intent to levy for
the 1997 and 1999 tax liabilities. In those Forms 12153,
petitioner argued:
Summarizing: I am requesting a “Due Process
Hearing” as outlined in Form 12153. I am “challenging
the appropriateness of (the) collection action” as
specified in 6330(c)(2)(A)(ii) since the IRS denied all
of my requests for the initial “examinations” and
“interviews” as provided for in Publications 1 & 5. In
addition, no lien for taxes pursuant to Code Sections
6321 and 6322 is possible because no valid, underlying
assessment was ever made. In addition, I never
received the statutory “notice and demand” for payment
of the taxes at issue as required by Code Sections
6203, 6321, and 6331. If the appeals officer is going
to claim that a particular document sent to me by the
IRS was a “Notice and Demand” for payment, then I am
requesting that he also provide me with a T.D. or
Treas. Reg. which identifies that specific document as
being the official, statutory “Notice and Demand” for
payment.
In addition, I am “challenging the existence of
the underlying tax liability” as I am authorized to do
in Code Section 6330(c)(2)(B). In addition, I did not
receive a (valid) notice of deficiency in connection
with any of the years at issue. I am also requesting
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