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married-separate because your spouse had previously
filed a separate return and the three-year period for
changing a separate return to a joint return had ex-
pired. You responded by filing Form 1040X for correc-
tions to the 1994 return due to a math error discovered
on Schedule A. No subsequent response was received
from you and assessment was made as previously proposed
in the report [30-day letter pertaining to petitioner’s
taxable year 1994] dated April 5, 1999. During the
Appeals hearing, you indicated that you currently
believe that you have no requirement to file any income
tax returns.
You raised no other relevant issues relating to the
unpaid taxes and made no proposals regarding collection
alternatives.
Balancing efficient collection and intrusiveness
IRC � 6330 requires that the Appeals Officer consider
whether any collection action balances the need for
efficient collection of taxes with the legitimate
concern that any collection action be no more intrusive
than necessary. You have not made payments toward
these outstanding liabilities [and] dispute having
income that could be used to do so. Significant re-
sources continue to be used to collect what you owe.
You have not provided any arguments but those the
Courts have consistently determined to be frivolous,
and have not presented any alternatives to the proposed
levy. Therefore, Appeals has determined the levy is
necessary for the efficient collection of the income
tax liability.
On December 31, 2001, petitioner filed a petition with the
Court for review of respondent’s notice of determination. The
petition contains statements, contentions, arguments, and re-
quests that the Court finds to be frivolous and/or groundless.
On March 28, 2002, respondent issued to petitioner a notice
of deficiency with respect to his taxable years 1996 and 1997.
As it pertains to petitioner’s taxable year 1996, that notice
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