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The taxpayer responded by submitting a Form 12153,
Request for a Collection Due Process Hearing, to the
Collection officer;
The taxpayer’s appeal was timely, being mailed on
11/2/01-The taxpayer is entitled to judicial review;
* * * * * * *
Both certified transcripts, and non-literal transcripts
were requested and reviewed by this A.O. Copies of the
certified transcripts were provided to the taxpayer. A
“face to face” CDP Hearing was offered to TP. * * * The
meeting was held on 4/18/2002. TP represented himself.
Issues Raised by the Taxpayer
In TP’s appeal request, TP’s arguments were plentiful
but without substance. They were of the type described
by the Courts as “frivolous.” * * * TP disputes the
receipt of an official notice of deficiency and other
procedural errors based on TP’s personal views and
conclusions of law. In my opinion, based on Court
decisions, those arguments have no merit. TP was
provided copies of court cases attesting to the fact
that the courts are tired of such arguments and could
sanction TP if they were brought forth in a judicial
hearing.
At the time of the conference, TP did not make a claim
he was an “innocent spouse.” * * * Nor did TP provide
any non-frivolous argument as to the steps taken by the
Collection division to obtain payment. TP did attempt
to offer questions regarding procedures, but such
questions were generally frivolous and had no bearing
on the outcome of the case. TP did not suggest that he
might become current in or correct his prior filings.
Nor did TP suggest any collection alternatives.
MY EVALUATION
Review of the information stated above and now present
in the administrative file shows the requirements of
all applicable laws and administrative procedures have
been met. Assessments were properly made. TP was
billed for and did not pay amounts due. The Compliance
Division proceeded with enforced collection action and
it appears they should be allowed to continue with the
action.
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Last modified: May 25, 2011