Larry A. Michael - Page 5




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                    If the appeals officer recommends “enforcement of                 
               collection action including levy,” without having                      
               produced these specific documents, then it will be                     
               obvious that the appeals officer is simply attempting                  
               to thwart and circumvent the Code Section 6330 in order                
               to enable the IRS to continue its practice of making                   
               the illegal seizures uncovered by the Senate Finance                   
               Committee, as referred to by Senator Roth in his book,                 
               and which THE “DUE PROCESS HEARING” was designed to                    
               eliminate.                                                             
               On February 26, 2002, the Appeals Officer, Robert L. Amick,            
          sent to petitioner a letter in which he suggested that a hearing            
          be held in March 2002 either in the IRS office in Sioux City,               
          Iowa, or in the Omaha Appeals Office in March 2002.  In addition,           
          the Appeals officer advised petitioner that he (the Appeals                 
          officer) requested certified transcripts of petitioner’s accounts           
          “to provide evidence that the amounts due do in fact exist.”                
          Petitioner responded to that letter on March 18, 2002.  He                  
          requested a hearing in late June or early July.  On March 19,               
          2002, the Appeals officer mailed to petitioner a letter in which            
          he suggested that petitioner set a meeting date and time by the             
          end of the month.  Enclosed with the letter were Forms 4340,                
          Transcripts of Assessments, Payments, and Other Specified                   
          Matters.  Forms 4340 were for petitioner’s taxable years 1994,              
          1995, and 1996, and were dated March 6, 2002.  The Appeals                  
          officer sent to petitioner four other letters on March 21, March            
          29, May 7, and June 7, 2002, respectively.  In his March 29,                
          2002, letter, the Appeals officer suggested that the hearing be             





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