-8-
decide whether you could remain working for such a
lawless organization as the IRS. If you would continue
working for the IRS then you would be willfully and
knowingly acting under the Color of Law, and would be
nothing less than a common criminal!
* * * * * * *
We also attached a copy of the Code of Federal
Regulations Parallel Table of Authorities. If you will
check, you will find all penalties, assessments,
authority to make returns for the taxpayer, are all in
Title 27, Alcohol, Tobacco, and Firearms, not in Title
26, Income Tax.
A face-to-face hearing was not held with petitioner.
Instead, on the basis of petitioner’s letters and attached
documents, and because of a failure by petitioner to set a date
or time for a hearing, Appeals issued to petitioner on July 16,
2002, a Notice of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330 for 1994, 1995, and 1996. This
notice reflected the determination of Appeals to sustain the
proposed levy on petitioner’s property.
Discussion
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). Summary judgment may be
granted with respect to all or any part of the legal issues in
controversy “if the pleadings, answers to interrogatories,
depositions, admissions, and any other acceptable materials,
together with the affidavits, if any, show that there is no
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