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with the procedures set forth in section 6330(c), (d), and (e).
See, e.g., Goza v. Commissioner, 114 T.C. 176, 179 (2000).
Section 6330 generally provides that the Commissioner cannot
proceed with collection by levy until the person has been given
notice and the opportunity for an administrative review of the
matter (in the form of an Appeals Office hearing); and, if
dissatisfied, the person may seek judicial review of the
administrative determination. Davis v. Commissioner, 115 T.C.
35, 37 (2000); Goza v. Commissioner, supra.
We review respondent’s determination for abuse of
discretion. Sego v. Commissioner, 114 T.C. 604, 610 (2000);
Hodgson v. Commissioner, T.C. Memo. 1998-70.
Petitioner’s allegations that respondent’s determination
“was both lawless and erroneous” can be summarized as follows:
(1) The lien notice was not signed by the Secretary or his
delegate; (2) the Appeals officer failed to obtain and present at
the hearing the verification from the Secretary required by
section 6330(c)(1); (3) petitioner never received a notice and
demand for payment from the Secretary; (4) “the Congress did not
authorize the assessment and/or collection of a ‘1040’ ‘Kind of
Tax’”; and (5) “the CDP hearing was a mockery and a farce and
provided none of the safeguards against illegal IRS seizures that
Congress envisioned when it enacted Code Sections 6320 and 6330.”
Petitioner’s allegations are frivolous and without any merit.
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